Draft Environmental Assessment Phoebe Sumter Medical Center Hospital Relocation Project Americus, Sumter County, Georgia FEMA-1686-DR-GA, PW No. 193 September 2009 U.S. Department of Homeland Security Federal Emergency Management Agency, Region IV Atlanta, Georgia Table of Contents Acronyms and Abbreviations v 1.0 Introduction 1-1 1.1 Project Setting and Background 1-1 1.1.1 Former Sumter Regional Hospital Site 1-5 1.1.2 Phoebe Sumter Medical Center Proposed New Hospital Site 1-5 1.2 Purpose of and Need for Action 1-13 1.3 Previous Study and Agency Coordination 1-14 2.0 The Site Selection Process 2-1 2.1 Site Selection Process 2-1 2.2 Alternatives Considered But Dismissed 2-1 2.3 Alternatives for Detailed Study 2-2 3.0 Affected Environment 3-1 3.1 Physical Environment 3-1 3.1.1 Geology and Hydrogeology 3-1 3.1.2 Geologic Hazards 3-3 3.1.3 Topography 3-3 3.1.4 Soils 3-6 3.1.5 Floodplain Management 3-10 3.2 Biological Environment 3-15 3.2.1 Plant Communities and Wildlife 3-17 3.2.2 Threatened and Endangered Species 3-17 3.2.3 Wetlands 3-19 3.2.4 Survey of Jurisdictional Streams 3-21 3.3 Human Environment 3-21 3.3.1 Land Use and Zoning 3-21 3.3.2 Demographics and Housing 3-27 3.3.3 Local Economy and Employment 3-28 3.3.4 Community Facilities and Services 3-31 3.3.5 Environmental Justice 3-32 3.3.6 Noise 3-33 3.3.7 Visual Resources 3-33 3.4 Cultural Resources 3-33 3.4.1 Historic Structures 3-33 3.4.2 Archaeology 3-34 3.5 Infrastructure 3-36 3.5.1 Water Supply 3-36 3.5.2 Wastewater Disposal 3-37 3.5.3 Other Public Utilities 3-37 3.5.4 Transportation 3-38 3.6 Hazardous Waste and Materials 3-40 3.6.1 Site Reconnaissance 3-40 3.6.2 Former Hospital Site Conditions 3-41 3.6.3 272-Acre Property Conditions 3-50 3.6.4 Records Reviews and Interviews 3-54 4.0 Environmental Consequences 4-1 4.1 Physical Environment 4-3 4.1.1 Geology and Hydrogeology 4-3 4.1.2 Geologic Hazards 4-3 4.1.3 Topography 4-4 4.1.4 Soils 4-4 4.1.5 Floodplain Management 4-5 4.2 Biological Environment 4-5 4.2.1 Plant Communities and Wildlife 4-5 4.2.2 Threatened and Endangered Species 4-6 4.2.3 Wetlands 4-7 4.3 Human Environment 4-7 4.3.1 Land Use and Zoning 4-7 4.3.2 Demographics and Housing 4-7 4.3.3 Local Economy and Employment 4-8 4.3.4 Community Facilities and Services 4-9 4.3.5 Environmental Justice 4-10 4.3.6 Noise 4-11 4.3.7 Visual Resources 4-11 4.4 Cultural Resources 4-12 4.4.1 Historic Structures 4-12 4.4.2 Archaeology 4-12 4.5 4.5 Infrastructure 4-13 4.5.1 Transportation 4-13 4.6 Hazardous Waste and Materials 4-14 4.6.1 No Action Alternative Conditions 4-14 4.6.2 Former Hospital Site Alternative Conditions 4-14 4.6.3 New Hospital Site Alternative Conditions 4-15 4.7 Summary of Environmental Consequences 4-15 4.8 Mitigation of Unavoidable Adverse Impacts Associated with the Alternatives 4-15 4.9 Relationship Between the Short-Term Use of the Environment and the Maintenance and Enhancement of Long-Term Productivity 4-15 4.10 Cumulative Impacts 4-16 4.11 Irreversible or Irretrievable Commitment of Resources 4-16 5.0 Public Involvement 5-1 6.0 Agency Coordination and Permits 6-1 7.0 Conclusions 7-1 8.0 References 8-1 Appendices Appendix A Site Photographs Appendix B Agency Coordination Appendix C Archaeological and Cultural Survey List of Tables Table 2-1: Impact Summary Matrix 2-4 Table 3-1: Former Hospital Site Soil Characteristics 3-6 Table 3-2: 272-Acre Property Soil Characteristics 3-8 Table 3-3: Proposed New Hospital Site Soil Characteristics 3-8 Table 3-4: USFWS Sumter County, Georgia Listed Threatened or Endangered Species 3-15 Table 3-5: Americus, Georgia – Commuting to Work Statistics (2000) 3-38 Table 3-6: LUST Sites Near Former Hospital Site 3-47 Table 3-7: UST Sites Near Former Hospital Site 3-49 Table 4-1: Environmental Consequences Impacts and Mitigation 4-1 Table 5-1: Public Meetings on Rebuilding the Sumter Regional Hospital 5-2 Table 52: List of Local Newspaper Articles Television News on Hospital Rebuilding 5-3 List of Figures Fig. 1-1: Vicinity Map 1-2 Fig. 1-2: Properties Map – Former Hospital Site, 272-Acre Property & Proposed New Hospital Site 1-3 Fig. 1-3: Topographic Map & Aerial Photo of Sumter Regional Hospital (SRH) Former Hospital Site 1-6 Fig. 1-4: Sumter Regional Hospital Former Hospital Site Plan 1-7 Fig. 1-5: Topographic Map and Aerial Photo – 272-Acre Property & Proposed New Hospital Site 1-8 Fig. 1-6: Parcel Map – 272-Acre Property & Proposed New Hospital Site Plan 1-10 Fig. 1-7: Proposed New Hospital Site Plan 1-11 Fig. 1-8: Utilities and Aerial Photo of 272-Acre Property & Proposed New Hospital Site 1-12 Fig. 3-1: Geologic Map of 272-Acre Property & Proposed New Hospital Site 3-2 Fig. 3-2: Topographic Map & Aerial Photo of Sumter Regional Hospital Former Hospital Site 3-4 Fig. 3-3: Topographic Map & Aerial Photo – 272-Acre Property & Proposed New Hospital Site 3-5 Fig. 3-4: Building Soil Map of Former Hospital Site 3-7 Fig. 3-5a: Farmland Soil Map of 272-Acre Property & Proposed New Hospital Site 3-9 Fig. 3-5b: Soil Hydrologic Map of 272-Acre Property & Proposed New Hospital Site 3-11 Fig. 3-5c: Building Soil Map of 272-Acre Property & Proposed New Hospital Site 3-12 Fig. 3-6: Flood Insurance Rate Map (FIRM) – 272-Acre Property & Proposed New Hospital Site 3-14 Fig. 3-7: Wetlands Map and Aerial Photo – 272-Acre Property & Proposed New Hospital Site 3-20 Fig. 3-8: Low Income and Minority Areas in Americus, Sumter County, Georgia 3-29 Fig. 3-9: Archaeological Survey of Proposed New Hospital Site 3-35 Fig. 3-10: Hazardous Waste and Materials Related to Former Hospital Site 3-46 Acronyms and Abbreviations ABFE advisory base flood elevation ACHP Advisory Council on Historic Preservation ACM asbestos containing materials AEC Americus Engineering and Construction AG Georgia State Attorney General amsl above mean sea level APE Area of Potential Effect Authority Americus and Sumter County Hospital Authority BFE Base Flood Elevation BMP Best Management Practice CAA Clean Air Act CEQ Council on Environmental Quality CFR Code of Federal Regulations CO carbon monoxide CWA Clean Water Act DAH Georgia Department of Archives and History dB decibel DEQ Georgia Department of Environmental Quality DFIRM Digital Flood Insurance Rate Map DNL Day-Night Average Sound Level DNR Georgia Department of Natural Resources DOT Georgia Department of Transportation EA Environmental Assessment EO Presidential Executive Order EPA U.S. Environmental Protection Agency EPD Environmental Protection Division (division of DNR) ESA Environmental Site Assessment FEMA Federal Emergency Management Agency FIPS Federal Information Processing Standard (G/NGO identification code) FIRM Flood Insurance Rate Map FPPA Farmland Protection Policy Act GASF Georgia Archaeological Site File GEMA Georgia Emergency Management Agency GSU Georgia State University GSWSU Georgia Southwestern State University Healthplex SRH Hospital Annex destroyed replaced with SHR East facilities HUD U.S. Department of Housing and Urban Development LEED Leadership in Energy and Environmental Design mph miles per hour NAAQS National Ambient Air Quality Standards NADB National Archaeological Database NEPA National Environmental Policy Act NESHAP National Emission Standards of Hazardous Air Pollutants Acronyms and Abbreviations (Continued) NFRAP No Further Remedial Action Planned List (related to CERCLIS) NGO Non-Governmental Organization NHPA National Historic Preservation Act NO2 nitrogen dioxide NPDES National Pollutant Discharge Elimination System NRCS Natural Resources Conservation Service of the USDA NRHP National Register of Historic Places NRIS National Register Information System NWI National Wetlands Inventory O3 ozone OSHA Occupational Safety and Health Administration PM10 particulate matter less than 10 microns PM2.5 particulate matter less than 2.5 microns PPHS Phoebe Putney Health System, Inc. PPMH Phoebe Putnam Memorial Hospital PSMC Phoebe Sumter Medical Center PW Project Worksheet PWD Public Works Department of the City of Americus, Georgia REC recognized environmental condition SHPO State Historic Preservation Office SO2 sulfur dioxide SPLOST Special Local Options Sales Tax SRH East Temporary Hospital on site of former SRH “Healthplex” facility SRH Sumter Regional Hospital SWPPP Storm Water Pollution Prevention Plan THPO Tribal Historic Preservation Officer USACE U.S. Army Corps of Engineers USCB U.S. Census Bureau USDA U.S. Department of Agriculture USFWS U.S. Fish and Wildlife Service WSS Web Soil Survey – USDA NRCS web site 1.0 Introduction The City of Americus (City) is the county seat of Sumter County, in southwest Georgia (Fig. 1-1). On March 1, 2007 a tornado destroyed Sumter Regional Hospital (SRH) and its annex “Healthplex” building, both on the city’s east side. By April 2008 a temporary hospital, SRH East, was built and began operations at the former Healthplex building site. A new, smaller replacement hospital facility, Phoebe Sumter Medical Center (PSMC), is planned to be built on the city’s west side. Fig. 1-2 shows the three properties’ locations. Because the replacement hospital is to be relocated to a new site, federal and FEMA policies define this proposed project as an “improved project”. Thus, the National Environmental Protection Act (NEPA) and related federal Public Laws, Presidential Executive Orders, and agency regulations require FEMA to evaluate the proposed project’s likely affects on the “human environment”. This Draft Environmental Assessment Report (DEA) was prepared to comply with NEPA and related laws, orders, and regulations. Figure 1-1 shows a Sumter County map situated in southwest Georgia, surrounded by adjacent counties. Figure 1-2 shows the city of Americus map with the locations of the Former Hospital, SRH East/Temporary Hospital and the Proposed New Hospital sites. The three properties are identified as follows and described more fully within this EA (Fig. 1-2). Phoebe Sumter Medical Center (PSMC) proposed “New Hospital” site Sumter Regional Hospital (SRH) destroyed “Former Hospital” site Temporary Hospital (SRH East) replaced destroyed “SRH Healthplex” annex site Since this disaster many local relationships to the hospital changed or evolved. The present status and future consequences of developments for the 76-bed New Hospital site for PSMC site and 143-bed SRH Former Hospital site are the primary properties of concern in this EA. 1.1 Project Setting and Background Sumter Regional Hospital (SRH), started in 1908 as an 8-bed hospital, grew by 2007 to a 143-bed acute care nonprofit facility, located in Americus, Sumter County, Georgia and owned by the Americus and Sumter County Hospital Authority (Authority). The Authority, incorporated in 1949, is also known as the Sumter Regional Hospital, a Non-Governmental Organization (NGO) with a Federal Information Processing Standard (FIPS) No. of 261UJ4LD00. The Authority has nine appointed board members: the Sumter County Commissioners appoint five members, and the City Council appoints four members. In 1991, the Authority leased Hospital management to a nonprofit company, Sumter Regional Hospital, Inc. (SRH Management Company). SRH Management Co. is a wholly-owned subsidiary of a nonprofit company, Southwest Georgia Healthcare Resources, Inc. The Hospital's service area is primarily Sumter County, but also 10 other local counties: Dooly, Schley, Macon, Lee, Marion, Taylor, Crisp, Stewart, Webster and Worth Counties. The Authority terminated SRH Management’s lease as of July 1, 2009. On March 1, 2007, the Hospital and its annex (Healthplex) building were severely damaged by a tornado that became part of a presidentially-declared disaster area, DR1686GA. Thus, the Hospital became eligible for disaster relief funding from the Federal Emergency Management Agency (FEMA) and the Georgia Emergency Management Agency (GEMA). Hospital operations were re-located to temporary facilities; FEMA-loaned metal frame structures set essentially on the footprint of the destroyed Healthplex building. The temporary Hospital opened on April 1, 2008 and is known as Sumter Regional Hospital East (SRH East). SRH East restored core medical, surgical, and labor and delivery services after a 13month break. SRH East has medical, surgical, pediatric, and intensive care services in addition to emergency, ancillary inpatient, and outpatient services on a 24hour basis. During the 13 months between the tornado and SRH East’s opening, local surgeons and other physicians had no work facilities in the City. Fourteen physicians relocated to other communities or closed their practices (AG, 2009). This depleted the Hospital's available funds and the changed the area’s classification to “medically unserved” (AG, 2009). In addition to the Hospital, the Authority also owns a medical office building, certain physician practices, and other SRH-related assets (collectively "related assets"). The Authority, as Lessor, began on July 1, 2009 a 40-year lease of the Authority Hospital and related assets to a newly-created entity, Phoebe Sumter Medical Center, Inc. (PSMC or Lessee) in Americus, Georgia. PSMC is a newly-formed Georgia nonprofit corporation and a wholly-owned subsidiary of Phoebe Putney Health System, Inc., in Albany, Georgia. The Authority and SRH’s original goal was to rebuild the hospital facilities and functions on their own, to remain independent, and to ensure continuation of the commitment to provide charity and indigent care to that large part of the service area's population. The disaster damages to the hospital facilities and loss of supporting professional services put a severe drain on the Authority’s finances. Although hospital rebuilding funds were due from insurance proceeds, and likely from FEMA and GEMA funding, the Authority did not have sufficient funds available to complete the replacement hospital construction. The Authority then sought suitable candidates to help finance and manage the rebuilding and recovery of the hospital facilities and professional services. The Authority selected Phoebe Putney Health System (PPHS) for the Hospital's long term viability. The transaction consisted of the following agreements: (1) a 40-year lease that includes the temporary SRH East facility and the replacement Hospital; (2) Core Services Agreement; (3) Hospital Construction Agreement; (4) Loss Minimization Plan; and (5) Transition Agreement (collectively, "Proposed Lease"). Hospital assets in the Proposed Lease transaction include the Hospital, a health clinic, certain medical office buildings and other assets. PPHS created a nonprofit wholly-owned subsidiary, PSMC, as Lessee. In the Proposed Lease, PPHS guarantees the financial obligations and commitments of PSMC, the Lessee (Authority, 2009). The Proposed Lease provides that PSMC will assume and pay the Hospital's current operating losses and indigent and charity care for Sumter County residents. PSMC also committed to rebuilding the Sumter County physician community. The Authority will retain legal title to the Hospital and to all leased property. 1.1.1 Former Sumter Regional Hospital Site The Former Sumter Regional Hospital site is about 0.6 miles east of the city center and included the destroyed SRH hospital and SRH Healthplex buildings. The interim/temporary hospital (SRH East) facilities were set on the Healthplex building footprint. It is bounded by residential properties to the west and north, and commercial properties to the south and east, that developed during the last 50 or so years (Fig. 1-3). Former Sumter Regional Hospital Site The former SRH site, at 100 Wheatley Drive, is a triangular 12.5acre property comprised of three lots (Fig. 1-3). It is bounded by East Forsyth Street on the south, a residential lot on the west, Oglethorpe Street on the northwest, East Jefferson Street on the north, and North Mayo Street on the east. This site was used for medical services from 1953 until the March 1, 2007 tornado disaster. The former SRH site plan shows the last major building addition in 1997 (Fig. 1-4). The present site use includes several modular office units on the site’s northeast corner, used by SRH East staff. Much of the Former Hospital parking lot pavement surface remains essentially intact. Since March 1, 2007, the Former Hospital building was demolished, the site cleared and graded close to the original ground surface elevation, with about 20,000 cubic yards of crushed concrete debris and gravel in two piles remaining near the middle of the site. Former SRH Healthplex & Present SRH East Site The former SRH Healthplex site, at 1048 East Forsyth Street, is an irregularly rectangular 9acre lot east of and adjacent to the destroyed SRH site. It is on a commercial block bounded by East Forsyth Street on the south, North Mayo Street on the west, East Jefferson Street on the north, and North Hudson Street on the east. A few small non-hospital commercial buildings/lots are at the southwest and northeast corners of this block. Until the replacement hospital is built and operational in 2011, the SRH East site’s 1048 East Forsyth Street, Americus, Georgia address will be PSMC’s mailing and operational address. SRH East site services and functions will be transferred to PSMC New Hospital site and unused infrastructure and facilities will be sold or returned to FEMA. 1.1.2 Phoebe Sumter Medical Center Proposed New Hospital Site Phoebe Putnam Health System recently purchased a 272-acre property 1.3 miles west of the city center (Fig. 1-5). The proposed PSMC New Hospital site is 45 acres of former farmland on the south-center area of the 272-acre property (Fig. 1-6). The City annexed the 45 acres and rezoned it, from (C-2: Commercial Overlay Zone) uses to hospital (I-N: Institutional Zone) use, in July 2009. Figure 1-3 shows a topographic map and aerial photo specifically for the Former Hospital site. Figure 1-4 shows an aerial photo and site design plans for the Former Hosptial site. Figure 1-5 shows a topographic map and aerial photo specifically for the 272-acre property where 45-acres are planned for the New Hospital site. The 272-acre property, including the new Hospital site, is bordered to the south by US Highway (US) 280, to the east by US19, and to the west by McMath Mill Road and Odom Road. The site is located in Land Lots 153, 154, 177, and 178 in the 27th Land District of Sumter County. The property is designated as Tax Parcel No. 2702 178 1, according to the Americus/ Sumter County GIS documents. The parcel is about 272.5 acres; about 213 acres are developable. About 59.5 acres of wetlands are in the 272-acre property’s northeast quadrant, limiting the property’s total buildable area (TTL, 2009). The 272acre property, 45acre new Hospital site plans, parcel boundaries, and wetlands area are in Fig. 1-6. The proposed main 4-story hospital building would be in the new Hospital site’s property’s north-central area, along with three nearby buildings on the south, for Womens, Oncology, and Wellness activities (Fig. 1-7, enlargement of site plans). The main entrance would be on the south from US280, and a secondary entrance would be off US19 on the east. Bounding latitude and longitude coordinates for the 272-acre property are: Southwest Corner: 32.0626  North, -84.2634  East Northeast Corner:  32.0736  North, -84-2481  East A Phase I Environmental Site Assessment report was completed for the 272-acre property January, 2009 (TTL, 2009c). An aerial photo in that report shows seven areas across the property (Fig. 1-8). Six geotechnical borings were drilled to 20 feet below ground surface for this site assessment (TTL, 2009b). The 272-acre property generally consists of heavily wooded areas (active farmlands in early 1900s), former pecan orchards, two utility easements, cleared trails, low lying areas with one significant intermittent stream and the Muckalee Creek floodplain. A private petroleum pipeline easement crosses the site from north to south, and a City of Americus sewer and water, power and natural gas easement crosses the site from west to east. A cellular telephone tower is in the outparcel at the property’s southeastern corner. The wooded area in the property’s northeast corner is mostly low lying with small streams and is in the Muckalee Creek floodplain. For discussion, the 272-acre property is divided into seven sections (Fig. 1-8): • Section 1 – south-central 13.1 acres, an upland pecan orchard. Section 1 comprises proposed New Hospital site south area). • Section 2 – southwest corner 16.5 acres, densely wooded with a swale running from west to east through the section’s middle. No standing or flowing water was observed in the section’s swale during TTL’s field work in December, 2008 (TTL, 2009b). • Section 3 – central-south 38.6 acres; uplands, heavily wooded with a strip of former pecan orchard on section’s southern edge. Standing water was observed in a swale just outside the section’s northwest corner. The lower part of Section 3 comprises most of proposed New Hospital site north area. • Section 4 – southwest-central 39.6 acres; uplands, densely wooded with hardwoods and planted pines. • Section 5 – northeast wetlands 43.4 acres; mostly in wetlands and the Muckalee Creek, has dense hardwood stands. A small unnamed intermittent stream enters from Section 6. Some water was observed in the swale in Section 5’s southwest corner, next to the Quality Inn property along US19/US280. • Section 6 – north-central, about 35 acres; mostly uplands, heavily wooded former pecan orchard in its northwest quadrant. A small unnamed intermittent stream originating in Section 7 enters Section 6 at the southwest corner and runs through the northern half of its eastern boundary and into Section 5. Standing or flowing water was noted in this intermittent streambed just east of the pipeline easement with increasing flows toward the east. The low lying area along the swale/ streambed in Section 6 is generally 100 to 200 feet wide. Groundwater seepage was noted at several locations at the base of adjacent ridges. • Section 7 – northwest 60.3 acres; generally uplands with dense woodlands in the southern half and a former pecan orchard in the northern half. An intermittent streambed originates in this section, runs into Section 6. No standing or flowing water was observed in the streambed. Figure 1-6 shows a parcel map for the 272-acre property and proposed New Hospital site plan along with the location of wetlands on the property. Figure 1-7 shows a parcel map for the planned 45-acre site for the proposed New Hospital with site plans. Figure 1-8 shows a recent aerial photo of the 272-acre property divided into 7 sections that are described in the text of the EA report. 1.2 Purpose of and Need for Action The Authority determined the SRH Former Hospital site is essentially “land-locked”, with limited potential and significant drawbacks for construction and future development, a difficult challenge for building a new hospital. The existing 12.5acre property only has the existing paved parking lot on the east side covering the more level building area, as the west side had the former 3-story hospital buildings with relatively steep slopes up to 12 degrees. Building on the steep slope would be difficult and more expensive. Expansion outside the existing 12.5 acres property would have to dislocate existing adjacent land owners. The property is surrounded by commercial properties on the south and east, and residential properties to the north and west. Purchase and dislocation of businesses within the existing developed commercial properties south of East Forsyth Street would be expensive. Dislocation of residential homes to the west and north of the site would also be expensive and have a potential negative cultural impact on the neighborhood. The SRH East site, east of the site, needs to remain in place with the temporary hospital facilities until the replacement hospital is built and operational. PPMS contracted engineering consulting firms to evaluate other potential suitable candidate hospital sites in and near Americus. Among the 8 suitable sites on the market, the candidate 272-acre former farmland and present wetland property on the city’s west side was determined to be the best choice for the New Hospital site (see Sec. 2.2). The 45-acres picked for hospital site is relatively flat and near the intersection of north-south US19 and the east-west US280, the two main transportation routes in Sumter County. Traffic to the New Hospital site should be less congested than the Former Hospital site. The west side of Americus has more farmland and less commercial and residential development. The distance of this site from the Americus city center is 1.3 miles, which is slightly more than the 0.6 mile of the former hospital site. It is also significantly above the Muckalee Creek 100-year floodplain area. 1.3 Previous Study and Agency Coordination In response to the March 2007 tornado disaster, several recovery activities were proposed by the City of Americus and Sumter County and their representatives on the Authority. FEMA initiated the environmental documentation process, in accordance with the National Environmental Policy Act of 1969, as amended (NEPA). NEPA was enacted by the U.S. Congress to require Federal agencies to consider the environmental impacts of Federal actions as part of the decision making process. Under NEPA, Federal agencies must conduct an investigation and evaluation of alternatives as part of the environmental documentation process, prior to making decisions that may impact the environment. Many other state and Federal agencies are involved, along with FEMA, in supporting the overall tornado recovery effort. Other agencies are participating by reviewing FEMA’s actions and documents to ensure that all potential NEPA compliance issues have been adequately addressed. It is FEMA’s goal to expedite and coordinate the development and review of NEPA documents in response to the needs of the communities in Sumter County devastated by the March 2007 tornado disaster, while meeting the intent of NEPA and complying with all NEPA requirements. To achieve this goal, FEMA has, from the onset, encouraged the participation of funding and review agencies, and the public in the proposed new Sumter Hospital NEPA compliance process. On September __, 2009, an Open House was held at Americus’ public meeting rooms at Rees Park, in the City of Americus, Georgia from 7:00 pm to 9:00 pm to provide the public the opportunity to comment on the Draft EA. Copies of the Draft EA were placed in three two information repositories located in the City of Americus, the Clerk’s Office in the Municipal Building and the Blackshear Regional Library, for a 21-day public review and comment period starting September 16th. The Draft EA could also be viewed and downloaded from FEMA’s website: http://www.fema.gov/plan/ehp/envdocuments/ea-region4.shtm. and aAds notifying the public of the availability of the Draft and Open HouseEA were placed in the Americus Times Recorder on September 11th and 15th. No substantive negative comments have yet to been received to date.[+r1] 2.0 The Site Selection Process This section describes project action and no action alternatives that were considered to address the purpose and need stated in Section 1.2. Two alternatives were evaluated in more detail: 2.1 Site Selection Process After the March 2007 disaster, the Authority sought funds and funding partners to rebuild the Sumter Regional Hospital. The Authority – PPHS partnership evaluated eight alternative locations. PPHS provided a lesson-learned from their Albany, Georgia, Phoebe Putney Memorial Hospital campus project. Properties surrounding their campus are fully developed and do not allow future expansion of the campus and related facilities. They recognized the Former Hospital site had a similar situation, surrounding properties were already developed for other uses and their existing site has steep slopes and a relatively small area for future expansion. 2.2 Alternatives Considered But Dismissed Several alternative sites were identified by local real estate brokers and were evaluated for feasibility for new hospital construction and future expansion. These included: Site 1 - 12.5-acre SRH (Former Hospital) site Site 2 - 272-acre property at intersection of US19 and US280 on west side of Americus (south-central 45-acre area for proposed New Hospital site) Site 3 - 124.46-acre property on US280 East Site 4 - 80.53-acre property on State Route 27 East Site 5 - 101.42-acre property on State Route 27 East Site 6 - 153.10-acre property on Southerfield Road Site 7 - 304.22-acre property on South Georgia Tech Parkway Site 8 - 301.35-acre property on US19 North and South Georgia Tech Parkway Site 9 - 197.37-acre property on US19 North Each of these sites were was evaluated based on the following criteria: location, size, terrain, traffic/highways, access to water and sewer utilities, zoning, and price. Access to utilities and the cost to bring utilities to each site were frequent issues. Site 1 – Former Hospital site was rejected because it is considered “land-locked” with limited potential for future expansion of hospital facilities and services, and patients’ site access is through a developed, congested area. Site 2 - 272-acre property to contain the south-central 45-acre are proposed New Hospital site was accepted as the preferred site because it is 1.3 miles from the city center, in an uncongested area, has access to major U.S. Highways 19 and 280 that pass through Sumter County, city utilities already pass through the site, and about 200 acres of uplands above Muckalee Creek wetlands allow for future hospital and city development. Site 3 - 124.46-acre property on US280 East was rejected mainly because of traffic, utilities, zoning, and price issues. Site 4 - 80.53-acre property on State Route 27 East was rejected because of location, traffic, utilities, and zoning issues. Site 5 - 101.42-acre property on State Route 27 East was rejected because of location, traffic, utilities, and zoning issues. Site 6 - 153.10-acre property on Southerfield Road was rejected because of traffic and zoning issues. Site 7 - 304.22-acre property on South Georgia Tech Parkway was rejected because of traffic and zoning issues. Site 8 - 301.35-acre property on US19 North and South Georgia Tech Parkway was rejected because of utilities and zoning issues. Site 9 - 197.37-acre property on US19 North was rejected because of utilities and zoning issues. Since sites 3 through 9 were rejected, this EA will not evaluate these sites in further detail. 2.3 Alternatives for Detailed Study There are three alternatives that will be considered in this EA: the No Action Alternative; the Former Hospital Site Alternative; and the Proposed New Hospital Site Alternative. Alternative 1: No Action The Former Hospital would not be replaced. Access to comparable service professional health care services would be available from the Phoebe Putney Memorial Hospital in Albany, about 36 miles south of Americus. Health care access would also be available from The Medical Center of Central Georgia, in Macon, about 75 miles northeast of Americus. The Georgia Southwestern State University (GSWSU) now has a contract for its 300 athletes to go to the Columbus Regional Healthcare System hospitals in Columbus, about 60 miles northwest of Americus. Its Houston Hospital has well respected sports injuries specialists (Young, 2009). Alternative 2: Rebuild Regional Hospital on Former Hospital Site The Authority determined the Former Hospital site is essentially “land-locked”, with limited potential and significant drawbacks for construction and future development, a difficult challenge for building a new hospital. The existing 12.5 acres property only had the existing paved parking lot on the east side covering the more level building area, as the west side had the former 3-story hospital buildings with relatively steep slopes up to 12 degrees. Hospital reconstruction on the steep slope would be difficult and more expensive. Plans may include rebuilding on the level east side where the parking lot exists, and parking on site in an expensive multi-story parking structure on the triangular-shaped and steep-sloped west side of the property. Alternative 3: Rebuild Regional Hospital on New Site (Proposed Action) The Authority evaluated eight potential New Hospital sites and chose the 272-acre property located on the west side of Americus. Among many other reasons the property has potential for additional development of the related health care facilities and has more immediate access to the regions’ main transportation arteries, US19 and US280. Figs. 1-6 and 1-7, respectively, show the location of the 45-acre south-central area proposed New Hospital site on the 272-acre property, and the proposed site plan for the New Hospital. The Authority also plans to build the New Hospital in accordance with modern LEED architectural standards to attract and retain top physicians. LEED, Leadership in Energy and Environmental Design, provides a suite of standards for environmentally sustainable construction, developed by the U.S. Green Building Council. Buildings and grounds are designed by trained and Green Building Certification Institute-certified professionals. LEED certified buildings often provide healthier work and living environments, that contributes to higher productivity and improved employee health and comfort. The initial capital cost for LEED construction, higher than conventional construction cost, is typically offset by the lower long-term operational and maintenance costs. As the Former Hospital site has limited property for construction, it may be difficult to feasibly achieve LEED building standards. The Authority provided the following “vision” for the eventual full development of the 272-acre property. “Phoebe Sumter Medical Center will be the nucleus of a medical destination for the citizens of Sumter County and surrounding communities, providing primary and enhanced health services for generations to come. The 272-acre property is adequate to accommodate projected growth. Medical office buildings, housing women’s and family services, oncology and surgical clinics, and wellness and outpatient rehabilitation, would be constructed first to stabilize the healthcare delivery system in this community. Other healthcare-related concerns and business, such as pharmacies, non-profit agencies and services, would be logical and encouraged elements for future growth. The proposed site plans include green spaces and perimeter walking trails to promote physical fitness. The development concept, therefore, is community-focused to meet immediate medical needs and simultaneously support productive lifestyle choices. By extension, the vision for the short- and long-term development addresses the healthcare elements and resources that enable people to maintain a high quality of life and productivity in the community where they live and work.” Table 2-1 summarizes the potential impacts associated with each of the three alternatives evaluated in this EA. No significant impacts were identified and potential adverse impacts can be effectively mitigated. Following a characterization of the affected environment, a detailed evaluation of the environmental consequences associated with each of the alternatives is provided in Section 4.0. Mitigation measures for potential adverse impacts associated with the alternatives are identified in Section 4.8. Table 2-1: Impact Summary Matrix Description No Action Alternative Former Hospital Site Alternative Proposed New Hospital Site Alternative Description of Alternative No hospital rebuilt using FEMA funds. Rebuild hospital on 12.5-acre Former Hospital site on developed east side of Americus northeast of intersection Mayo St. & Forsyth St. Rebuild hospital on Proposed 45-acre New Hospital site on undeveloped west side of Americus at intersection of US19 and US280. Potential Impacts Geology and Hydrogeology No effect. Short term Minor impact from earthmoving and excavation. BMPs should be employed to reduce potential for erosion and runoff during construction. Short term Minor impact from earthmoving and excavation. BMPs should be employed to reduce potential for erosion and runoff during construction. Geologic Hazards No effect. Design and construction BMPs will minimize sinkhole formulation. Design and construction BMPs will minimize sinkhole formulation. Topography No effect. No Minor effect from site grading. No Minor effect from site grading. Soils NMinoregligible impact: continued loss of soil from stormwater and wind. Development and site drainage plans need to account for limitations associated with west side site soil with steep slopes eroding. Need to follow sediment and erosion control practiceBMPs. Development and site drainage plans need to account for limitations for some site soils to erode. Need to follow sediment and erosion control practiceBMPs. Landscaping should be completed with vegetation capable of reducing stormwater runoff to downgradient wetland areas and Muckalee Creek. Floodplain Management No effect. Construction of hospital would comply with EO 11988 and FEMA regulations. Construction of hospital would comply with EO 11988 and FEMA regulations. Prime and Other Important Farmland No effect: no agricultural land affected. No effect: no prime or other important agricultural farmland affected, rebuilt hospital on existing urban land. Negligible impact: loss of insignificant amount of prime and important farmland. Plant Communities and Wildlife No effect: existing open space use would continue. No Minor effect: rebuilt hospital on older developed urban land, following tornado disaster demolition cleared site of vegetation. Short term Minor impact from earthmoving and excavation. BMPs should be employed to reduce potential for erosion and runoff during construction to protect downgradient wetland areas and Muckalee Creek. Threatened and Endangered Species No effect: existing open space use would continue. No effect: no threatened or endangered species known to exist on the site. No effect: no threatened or endangered species known to exist on the proposed 45-acre site. BMPs should be employed to reduce potential erosion and urban runoff to potential threatened or endangered species in downgradient wetland areas and Muckalee Creek. Wetlands No effect: existing open space use would continue. No effect: no wetlands exist on the site. No effect: no wetlands exist on the proposed 45-acre site. BMPs should be employed to reduce potential erosion and urban runoff to potential threatened or endangered species in downgradient wetland areas and Muckalee Creek. Jurisdictional Streams No effect: no existing open space use would continue. No effect: no jurisdictional streams exist on the site. No effect: no jurisdictional streams exist on the site. BMPs should be used to reduce potential erosion and sedimentation in downgradient, jurisdictional streams off site. Land Use and Zoning No effect. No effect: site used for 57 years for regional hospital. No Minor effect: July 2009 City of Americus annexed and rezoned 45-acre site for hospital (I-N: Institutional Zone). Demographics and Housing Adverse impact: existing healthcare professionals and supporting staff and businesses would leave region. No effect: existing and recruited healthcare professionals, supporting staff, and businesses would return to support hospital and community growth. Limited change for demographics and housing. Beneficial effect: existing and recruited healthcare professionals, supporting staff, and businesses would return to support new hospital and community growth. It would also improve housing and business development of lands to west side of Americus. Local Economy and Employment Adverse impact: existing healthcare professionals and supporting staff and businesses would leave region. No effect: existing and recruited healthcare professionals, supporting staff, and businesses would return to support hospital and community growth. Limited change for demographics and housing. Beneficial effect: existing and recruited healthcare professionals, supporting staff, and businesses would return to support new hospital and community growth. It would also improve housing and business development of lands to west side of Americus. Community Facilities and Services Adverse impact: existing healthcare professionals and supporting staff and businesses would leave region. Significant supporting tax base and community services likely to decline. No effect: continued same level of facilities and services. Beneficial effect: expected increase in level of facilities and services to community as housing and business develop lands on west side of Americus anchored by Proposed New Hospital site. Environmental Justice Adverse impact: no hospital nearby to maintain health of community. Low-income populations may not afford to travel to remote healthcare facilities. No effect: continued same level of local hospital facilities and services at same site. No effect: continued same level of local hospital facilities and services at site location 0.7 mile further from Americus city center than Former Hospital site. Noise No effect: existing open space use would continue. Temporary impact: construction. Temporary impact: site preparation selected removal of forest and regrading activities, and buildings construction. Visual Resources No effect: existing open space use would continue. Beneficial impact: additional planting of trees and landscaping will enhance neighborhood. Beneficial impact: on-site hospital building and landscaping using LEED design standards will enhance productive "Green" living and working conditions. Historic Structures No effect: existing open space use would continue. No effect: March 2007 tornado disaster and site demolition cleared site of potential historic structures. No effect: no historic structures identified on this 45-acre former farm site unused for about 41 years. Archaeology No effect: existing open space use would continue. No effect: March 2007 tornado disaster and site demolition cleared site of potential artifacts. No effect: no artifacts identified on this 45-acre site used for farming for at least 44 years and unused for at least 41 years. Water Supply No effect. No effect. No effect. Wastewater Disposal No effect. No effect. No effect. Other Public Utilities No effect. No effect. No effect. Transportation No effect. No effect. No effect. Hazardous Waste and Materials Potential significant effect: unknown extent and type of soil and possibly groundwater contamination from former USTs. Soil borings and monitoring wells on site will confirm contamination. Remediation may be required. Potential significant effect: unknown extent and type of soil and possibly groundwater contamination from former USTs (RECs). Soil borings and monitoring wells on site will confirm contamination with state agencies. Remediation may be required before construction of replacement hospital. No effect: no evidence of hazardous waste and materials on the 45-acres Proposed New Hospital site. 3.0 Affected Environment This section presents information on the existing physical, biological, social and cultural environments, and other environmental disciplines that have been evaluated so far. 3.1 Physical Environment 3.1.1 Geology and Hydrogeology Georgia Coastal Plain Geology and Hydrogeology The City of Americus is in the northern part of the Atlantic/Gulf Coastal Plain geomorphic/physiographic province, which covers Georgia’s southern half (Fig. 3-1). It consists of alluvial and sedimentary rock formations, from materials eroded from the igneous and metamorphic rocks of the older Blue Ridge and Piedmont Provinces to the north, and deposited since the Triassic Period 250 million years ago. The oldest geologic units exposed in Georgia’s Coastal Plain are in a strip south of the “Fall Line”, across the middle of the state, and are from the Late Cretaceous period, about 100 to 65 million years ago. Americus and Sumter County are in the middle of the Fall Line Hills District of Georgia’s Coastal Plain physiographic province. The Fall Line Hills District is characterized with land that is highly dissected, with little level land except in the marshy floodplains and their better drained, narrow stream terraces. Stream valleys are usually about 50 to 250 feet below adjacent ridge tops (DNR, 1976). Americus Area Geologic Units Americus area geologic units at the surface are from the Late Eocene to Early Oligocene Epochs, deposited about 40 to 20 million years ago. For the proposed 272-acre property, Late Eocene units are in lower areas along Muckalee Creek (Fig. 3-1; USGS, 1976). Early Oligocene units are in hillsides’ higher elevations (Carter, 2009). These units have been exposed to surface and near surface weathering processes for thousands of years, so local geologists usually define the units at surface as residuum (residues or residual soils) of the original deposits, now usually quartz grains and kaolin-type clays. The Former Hospital Site’s exposed geologic units are also Eocene-Oligocene Residuum. The Eocene Age Claiborne undifferentiated sedimentary unit covers about 40 percent of the 272-acre property, in the northeast. This unit’s primary rock type is sandstone, secondary type is clay or mud, and tertiary type is limestone (Fig. 3-1; USGS 2009). Figure 3-1 shows a basic geologic map for the 272-acre property with 2 geologic units as described in the EA report. An inset on the figure shows a basic geologic map of Georgia showing the distribution and structure of primary geologic units. The Eocene-Oligocene Residuum undifferentiated, weathered sedimentary unit covers about 60 percent of the 272-acre property, in the southwest. The primary rock type is sand and the secondary type is clay or mud (USGS, 2009). The recent Quaternary Alluvium is not shown on the map as it represents a thin and narrow deposit of clays, silts, and sands along Muckalee Creek, from more recent erosion within the watershed. Limestone is rarely found in Late Eocene and Early Oligocene unit surface exposures, as limestone is made mostly of calcium carbonate and dissolves as naturally acidic rainwater percolates downward and groundwater flows through the units. Small to large residual chert boulders are commonly found in the Americus area’s Early Oligocene units (Carter, 2009). Americus area water supplies are usually from groundwater wells. The Georgia Coastal Plain has several major aquifers, from youngest to oldest, the Floridan, Clairborne, Clayton, and Cretaceous aquifers (Fig. 3-1). The Floridan aquifer is absent in the Americus area. Americus area wells pump groundwater from the shallow Claiborne aquifer (if present), and the deeper Clayton and Cretaceous aquifers (USGS, 1986). 3.1.2 Geologic Hazards Georgia Coastal Plain geologic hazards include sinkholes and coastal erosion. Sinkholes form in limestone bedrock areas when subsurface dissolution creates cavities that lead to surface collapse. Examples exist in areas around Albany and Plains, Georgia. However, no sinkholes have been identified in the Americus area (Carter, 2009). 3.1.3 Topography Former Hospital Site Topography The Former Hospital site’s east side is on a hilltop and its west side is on a hillslope (Fig. 3-2). The hospital parking lot was on the east side’s flatter 2 to 8 percent grade hilltop. The hospital buildings were mostly on the west side’s steeper 8 to12 percent grade hillslopes. Site elevation ranges from about 460 feet to 395 feet above mean sea level (amsl), from the site’s northeast to southwest corners. Surface water runoff flows westward from the site to an unnamed tributary streambed of Muckalee Creek. Figure 3-2 shows a topographic map and an aerial photo of the Former Hospital site. 272-Acre Property Topography The 272-acre property is along the west side of Muckalee Creek. Elevations range from 430 to 420 feet amsl, respectively, at high points in the property’s northwest and southwest corners, to about 315 feet amsl elevation at Muckalee Creek (Fig. 3-3). An unnamed intermittent stream/streambed starts at about 375 feet amsl near the property’s center. Most of this property’s surface water runoff drains into this streambed, which flows northeast, and drains into Muckalee Creek, which flows southeast. Four smaller drainage areas, from about 10 to 30 acres each, are in the property’s corners, and also drain into Muckalee Creek. Figure 3-3 shows a topographic map and an aerial photo of the 272-acre property. New Hospital Site Topography The topography of the 45-acres proposed New Hospital site ranges in elevation from 431 feet amsl near the center of the site and about 380 feet amsl at the site’s northwest corner, near the unnamed intermittent streambed. All surface water drainage is radially away from the 431 feet elevation high point, where the main hospital building is planned to be built. 3.1.4 Soils Soil associations have a distinctive and proportional pattern of soils, normally consisting of one or more types of soils. The soils are different at each project site. The following soil descriptions from the U.S. Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS, 2009). Former Hospital Site Soils Former Hospital site soils are of two types, the Greenville (57 percent) and Tifton (43 percent) (Fig. 3-4). Greenville soil consists of sandy clay loam and is characterized with somewhat steep slopes of 8 to 12 percent and severely eroded. It is found on the site’s west side, essentially where the Former Hospital buildings existed. Tifton soil consists of sandy loam and is characterized with slopes ranging from 2 to 8 percent that may be eroded. It is found on the site’s east side where much of the Former Hospital’s paved parking lot still exists . Based on NRCS WSS GIS analysis, the Greenville soils area is rated to have a “very limited” capacity for constructing small commercial buildings. The Tifton soils area has a “somewhat limited” or “not limited” capacity for construction. Figure 3-4 shows an aerial photo of the Former Hospital site and the distribution of soil types. Table 3-1: Former Hospital Site Soil Characteristics Map Unit Symbol Percent of Area Map Unit Name & Summary Description Farmland Rating Infiltration Drainage Rating Building Rating GqD3 57 Greenville sandy clay loam, 8 to 12 % slopes, severely eroded (west side site – hospital bldgs.) Not Prime Farmland B – Moderate Rate Very Limited TuB2 TuC2 43 19.5 % Tifton sandy loam, 2 to 5 % slopes 23.9 % Tifton sandy loam, 5 to 8 % slopes (east side site – parking lots) All areas are prime farmland B – Moderate Rate Not Limited Somewhat Limited Total 100 272-Acre Property Soils The 272-acre property soils are mostly four types: Kinston and Bibb, Lucy loamy sand, Lakeland sand, and Orangeburg loamy sand (Figs. 35a, 3-5b and 3-5c, respectively), showing soil characteristics for farmland, hydrologic-infiltration capacity, and capacity for commercial buildings. These characteristics are summarized for the 272-acre property (Table 3-2) and for the 45-acre south-central area for the proposed New Hospital site (Table 3-3). Figure 3-5a shows an aerial photo of the 272-acre property and the distribution of farmland soil types. Figure 3-5b shows an aerial photo of the 272-acre property and the distribution of hydrologic soil types. Figure 3-5c shows an aerial photo of the 272-acre property and the distribution of building soil types. Table 3-2: 272-Acre Property Soil Characteristics Map Unit Symbol Percent of Area Map Unit Name & Summary Description Farmland Rating Infiltration Drainage Rating Building Rating Kib 21 Kinston and Bibb soils (within wetlands areas) Not Prime Farmland B/D - Moderate to Very Slow Rate (drained/undrained) Very Limited LMC 20 Lucy loamy sand (central area of site) Farmland of statewide importance A – High Rate Somewhat Limited LpC LpE 10 8 % Lakeland sand, 0 to 8 % slopes 2 % Lakeland sand, 8 to 17% slopes (both found between wetlands and main property area) Not Prime Farmland A – High Rate Not Limited Very Limited OeA OeB OeC2 OeD2 45 9.8 % Orangeburg loamy sand, 0 -2 % slopes 16.6% Orangeburg loamy sand, 2 - 5 % slopes 16.2 % Orangeburg loamy sand, 5 - 8 % slopes, eroded 2.5 % Orangeburg loamy sand, 8 - 12 % slopes, eroded (found west and south areas) Prime Farmland Prime Farmland Prime Farmland Farmland of statewide importance B – Moderate Rate Not Limited Not Limited Somewhat Limited Very Limited Total 96 Table 33: Proposed New Hospital Site Soil Characteristics Map Unit Symbol Percent of Area Map Unit Name & Summary Description Farmland Rating Infiltration Drainage Rating Building Rating LMC 30 Lucy loamy sand (central area of site) Farmland of statewide importance A – High Rate Somewhat Limited OeA OeB OeC2 70 Orangeburg loamy sand, 0 -2 % slopes Orangeburg loamy sand, 2 - 5 % slopes Orangeburg loamy sand, 5 - 8 % slopes, eroded Prime Farmland Prime Farmland Prime Farmland B – Moderate Rate Not Limited Not Limited Somewhat Limited 272-Acre Property Farmland Character The New Hospital site was used many decades for farmland, except for the Muckalee Creek wetlands area and the wetlands area associated with the unnamed intermittent streambed, that starts at the site’s center and extends northeast to Muckalee Creek. Based on the NRCS WSS GIS analysis the property farmland characteristics are (Fig. 3-5a): 43 percent - Prime Farmland 25 percent - Farmland of Statewide Importance 32 percent - Not Prime Farmland (wetlands areas and wetland slopes) Proposed New Hospital Site Farmland Character The proposed 45-acre New Hospital site construction will be entirely within designated Prime Farmland. 272-Acre Property Hydrologic Infiltration Drainage The soil hydrologic infiltration capacity for different soils is shown on Fig. 3-5b. There are three main soil infiltration ratings at the 272-acre property as follows: 30 percent – High Infiltration Rate (low runoff rate) 48 percent – Moderate Infiltration Rate 21 percent – Moderate to Very Slow Infiltration Rate for drained/undrained soils New Hospital Site Hydrologic Infiltration Drainage The 45-acres New Hospital site will be built almost entirely overlying Orangeburg loamy sand soils with high infiltration rates. About 3 acres northwest of the planned main hospital building will be built on Lucy loamy sand soils also with high infiltration rates. 272-Acre Property Buildings Construction Site soil mapping (Fig. 3-5c) indicates about 74 percent (about 201 acres) of the 272acre property has soils with somewhat limited to not limited characteristics for commercial building construction, based primarily on inherent soil character and gentle ground surface slopes ranging from 2 to 8 percent. The remaining 26 percent (about 71 acres) appear to have a very limited characteristic for small commercial building construction, with slopes ranging from 8 to 17 percent, but mostly due to wetland areas and flooding along Muckalee Creek. New Hospital Site Buildings Construction The proposed New Hospital 45-acre site is in the 272-acre property’s south-central area. Elevations here range about 20 feet, from about 430 to about 410 feet amsl. This is a flatter area for hospital facility construction and operation than the Former Hospital site, where building area elevations range about 50 feet, from about 460 to about 410 feet amsl. 3.1.5 Floodplain Management The City of Americus is upstream of the middle of the Muckalee Creek Watershed (02356000), which has a total area of 234,070 acres, or 366 square miles. The original city boundary line, circa 1830s, was a 2.5 mile diameter circle centered about one mile east from Muckalee Creek. Muckalee Creek flows southward and ends at Lake Worth, north of Albany, part of the larger Flint River Watershed. The Flint River Watershed at Albany, along with other tributary watersheds, has a total area of 5,285 square miles (UGA, 2005). Former Hospital Site The Former Hospital site lies entirely above the 100-year floodplain zone on the east side of Americus. New Hospital Site About 30 acres of the 272-acre property are in an “AE” 100-year special flood hazard area (zone), with flood elevations from about 331-feet to 332-feet amsl (Fig. 3-6 ;6; FEMA, 2009 Map No. 13261C0134C). Much of flood hazard area coincides with the USACE designated wetlands area. The New Hospital site’s 45-acre area is about 600 feet southwest of Muckalee Creek’s floodplains and wetlands, and about 2400 feet southwest of Muckalee Creek. The New Hospital site is planned to be at about 410 to 430 feet amsl, or about 80 to 100 feet above the creek’s 332-feet amsl 100-year flood elevation. About 60 acres of the 272-acre property’s northeastern corner along Muckalee Creek and in designated wetland areas are within the 100-year floodplain. Presidential Executive Order (EO) 11988 requires Federal agencies to take action to minimize floodplain occupancy and modification. Specifically, EO 11988 prohibits Federal agencies from funding construction in the 100-year floodplain unless there are no practicable alternatives. FEMA’s regulations for complying with EO 11988 state that FEMA is prohibited from funding construction in the 500-year floodplain for “critical actions,” which includes senior housing (44 CFR Part 9). FEMA applies an 8-Step Decision-Making Process to ensure that it funds projects consistent with EO 11988. By its nature, the NEPA compliance process involves the same basic decision-making process as the 8-Step Decision-Making Process. Therefore, the 8-Step Decision-Making Process has been applied through implementation of the NEPA process, and is documented in this EA. The City of Americus participates in the National Flood Insurance Program (NFIP) and therefore must adhere to NFIP floodplain management requirements. Regulations necessitate that new construction of residential structures be built with the lowest floor of the structure at an elevation equal to or above the estimated 100-year flood elevation, which is called the base flood elevation (BFE). The City of Americus Floodplain Management Ordinance requires the lowest floor of the structure to be at least 1 foot above the structure site’s BFE. Figure 3-6 is a FEMA floodzone map for the 272-acre property area on the west side of Americus. 3.2 Biological Environment The following table lists the threatened or endangered species identified by the U.S. Fish and Wildlife Service for Sumter County, Georgia. Since this list was completed in 2004 the Bald Eagle has been delisted as a federally threatened species. Table 34: USFWS Sumter County, Georgia Listed Threatened or Endangered Species Listed Species in Sumter County, Georgia (updated May 2004) Species Federal Status State Status Habitat Threats Bird   Bald eagle Haliaeetus leucocephalus T E Inland waterways and estuarine areas in Georgia.  Major factor in initial decline was lowered reproductive success following use of DDT. Current threats include habitat destruction, disturbance at the nest, illegal shooting, electrocution, impact injuries, and lead poisoning. Red-cockaded woodpecker Picoides borealis E E Nest in mature pine with low understory vegetation (<1.5m); forage in pine and pine hardwood stands > 30 years of age, preferably > 10" dbh Reduction of older age pine stands and to encroachment of hardwood midstory in older age pine stands due to fire suppression Reptile Alligator snapping turtle Macroclemys temminckii No Federal Status T Rivers, lakes, and large ponds near stream swamps. Destruction and modification of habitat and overharvesting. Barbour's map turtle Graptemys barbouri No Federal Status T Restricted to the Apalachicola River and larger tributaries including the Chipola, Chattahoochee, and Flint Rivers in eastern Alabama, western Georgia, and western Florida.   Gopher tortoise Gopherus polyphemus No Federal Status T Well-drained, sandy soils in forest and grassy areas; associated with pine overstory, open understory with grass and forb groundcover, and sunny areas for nesting Habitat loss and conversion to closed canopy forests. Other threats include mortality on highways and the collection of tortoises for pets. Invertebrate Gulf moccasinshell mussel Medionidus pencillatus E E Medium streams to large rivers with slight to moderate current over sand and gravel substrates; may be associated with muddy sand substrates around tree roots Habitat modification, sedimentation, and water quality degradation (Continued) Oval pigtoe mussel Pleurobema pyriforme E E River tributaries and main channels in slow to moderate currents over silty sand, muddy sand, sand, and gravel substrates Habitat modification, sedimentation, and water quality degradation Purple bankclimber mussel Elliptoideus sloatianus T T Main channels of ACF basin rivers in moderate currents over sand, sand mixed with mud, or gravel substrates Habitat modification, sedimentation, and water quality degradation Shiny-rayed pocketbook mussel Hamiota subangulata E E Medium creeks to the mainstems of rivers with slow to moderate currents over sandy substrates and associated with rock or clay Habitat modification, sedimentation, and water quality degradation Fish Bluestripe shiner Cyprinella callitaenia No Federal Status T Brownwater streams   Plant Buckthorn Sideroxylon  thornei No Federal Status E Oak flatwoods where soil normally is saturated for long periods after floods/heavy rain (i.e., calcareous swamps; woods bordering cypress ponds)    Canby's dropwort Oxypolis canbyi  E E Peaty muck of shallow cypress ponds, wet pine savannahs, and adjacent sloughs and drainage ditches Loss or alteration of wetland habitats Harper Fimbry Fimbristylis perpusilla No Federal Status E Muddy bottoms and silty margins of drying pine barren ponds and farm ponds   Hirst's panic grass Panicum hirstii Candidate Species E Small seasonally wet ponds (limestone depression ponds and shallow cypress ponds) Parrot pitcher-plant Sarracenia psittacina No Federal Status T Acid soils of open bogs, wet savannahs, and low areas in pine flatwoods   (Continued) Sweet pitcher-plant Sarracenia rubra No Federal Status E Acid soils of open bogs, sandhill seeps, Atlantic white-cedar swamps , wet savannahs, low areas in pine flatwoods, and along sloughs and ditches   White trumpet Sarracenia leucophylla No Federal Status E Acid soils of open bogs and on sphagnum mats in light gaps along streams and in red maple-blackgum swamps   Source: USFWS, 2004, Listed Threatened and Endangered Species in Sumter County, Georgia (2009) 3.2.1 Plant Communities and Wildlife Former Hospital Site The Former Hospital site is a highly disturbed urban lot. The west half, where the destroyed hospital buildings existed, consists of disturbed or regraded soils along with about 20,000 cubic yards of crushed concrete and highly disturbed “urban soils” associated with the buildings’ demolition in two piles. The east half is the former hospital’s asphalt-paved parking lot. 272-Acre Property The 272-acre property is primarily former farmland, now mostly secondary growth woodlands, and about 60 acres of wetlands in the northeastern corner (Section 3.2.3). In December 2008, a partial field biology reconnaissance was conducted on the 272-acre property (TTL, 2009a). Based on review of historical aerial photos of the 272-acre property, about 200 acres outside of wetlands were used for productive farmland for many decades until about mid-1960. During the last 50 or so years, typical mixed hardwood-pine secondary growth woodlands have covered most of the site. 3.2.2 Threatened and Endangered Species Conclusions – Survey of Threatened or Endangered Species and Habitat 272-Acre Property The species listed in Table 3-4 were not observed during the field survey of the 272-acre property done in December 2008. Based upon field observations, review of published literature, and database information, it is possible that habitat suitable to support threatened or endangered reptile, fish and invertebrate species may exists along the Muckalee Creek and adjacent floodplain. Since the survey was done in December, some plant species may not have been detected because they were dormant or not growing. Although habitat exists that may support threatened or endangered species, the areas exhibiting the most potential are within wetlands, especially along Muckalee Creek. These areas are not well suited for development and must be protected during and after project construction. Potential options include, but not limited to well marked construction limits of disturbance, state-approved erosion and sediment control measures, [etc.]. The listed plant species, based upon their habitat condition requirements and tolerance ranges, naturally exist mostly to entirely within wetlands and other areas with wetland water regimes, and rarely to never naturally exist outside such wet areas (USACE, 1987 and USDA, 2009). New Hospital Site The proposed New Hospital site’s 45 acres are on higher ground near a hilltop, and entirely on Orangeburg loamy sand soils with high infiltration rates, an area very unlikely support any of these listed plant species. The site was formerly used for farmland up to about 1968. An old unused orchard with pecan trees lies on the south third of the site.  The north two-thirds of the site has a secondary growth woodlands, about 41 years old.  The New Hospital is planned to be constructed in the middle of the site on top of the hill. No wetlands are located on this 45-acre site, so no species with wetland habitat areas will be affected.  The woodlands are young, so it not old enough to satisfy the habitat needs for the Red Cockaded Woodpecker. Red Cockaded Woodpecker The only woodpecker to excavate its home in living pine trees, the red-cockaded woodpecker (RCW) (Picoides borealis) was probably a common resident of mature southeastern U.S. pine forests at one time. However, populations of this non-migratory species have drastically declined, and the bird is now listed as endangered under the Endangered Species Act (ESA) because most of its required habitat has been altered through clearing, urbanization, incompatible forestry practices, and lack of periodic fire to maintain the pine stands in an open condition. Most remaining RCWs exist on public lands such as national forests, national wildlife refuges, and military bases where large tracts of woodland habitat have been maintained in suitable condition. Many of these public land populations are under intensive management in an attempt to increase RCW numbers and recover the species from its endangered status. In Georgia, the largest public land populations are found at Fort Benning, Fort Stewart, Okefenokee National Wildlife Refuge, and Piedmont National Wildlife Refuge/Oconee National Forest/Brender Demonstration Forest. Some RCWs also remain on private land in Georgia. The Red Hills region of Thomas and Grady counties supports a substantial RCW population. Suitable habitat has been maintained incidentally on adjacent large tracts of private land managed primarily for bobwhite quail. Most of the other RCWs on private lands, however, belong to small, isolated populations on relict fragments of habitat. Survey Results - Mature stands of pine species were not observed within the survey area. The RCW habitat descriptions presented in the literature and on State, Federal and academic internet websites was not observed within the corridor reviewed for this survey. 3.2.3 Wetlands Presidential Executive Order 11990 for wetlands protection requires Federal agencies to take action to minimize wetland loss. The NEPA compliance process requires federal agencies to consider direct and indirect impacts on wetlands that may result from their federally-funded actions. Application of the Eight-Step Decision-Making Process is required to ensure that federally-funded projects are consistent with EO 11990 objectives. The National Wetlands Inventory was used to identify USACE designated wetlands areas as described below (USFWS. 2009). This information was combined with a recent wetlands delineation survey for the 272-acre property (Lanier, 2008). Former Hospital Site The Former Hospital site lies above any designated wetland areas on the east side of Americus. 272-Acre Property About 30 acres of the 272-acre property’s northeastern corner along Muckalee Creek are in PFO1C wetlands (USFWS, 2009). “PFO1C” wetlands are Palustrine Forested Broad-leaved Deciduous Seasonally Flooded wetlands, a somewhat common wetland type along Muckalee Creek. A wetlands survey was done on the 272-acre property in December 2008 (Lanier, 2008). The survey focused on potential wetlands areas near the unnamed intermittent stream/streambed that starts near the property’s center and drains northeast into Muckalee Creek. The survey concluded the 272acre property has a total of about 60 acres of wetlands in its northeast corner, including the approximately 30 acres of PFO1C wetlands (USACE, 1987 and USFWS, 2009). A wetlands map and aerial photo (Fig. 37) combine the USACE designated wetlands and recently surveyed wetlands (Lanier, 2008), for a total of about 59.5 acres of wetlands (TTL, 2009b), and the unnamed intermittent streambed’s surveyed alignment (Lanier, 2008). The USACE reviewed the recent survey and concluded the 59.5 acres are federally designated wetlands (Appen. B). New Hospital Site The New Hospital site’s 45 acres are above identified wetlands areas. Figure 3-7 is a wetlands map and aerial photo of the 272-acre property and proposed New Hospital site, showing no wetlands exists on the 45-acre site. 3.2.4 Survey of Jurisdictional Streams The U.S. Army Corps of Engineers (USACE) is the federal agency responsible for protecting wetlands and the water quality in streams nationwide. The Georgia EPD is permitted by the USACE, through the Clean Water Act (CWA) to monitor and jurisdiction to enforce federal and state water quality regulations. The following are simple definitions of the common U.S. stream types: Perennial Stream - A stream that flows in a well-defined channel throughout most of the year under normal climatic conditions. lntermittent Stream - A stream that flows in a well-defined channel during wet seasons of the year but not for the entire year. Ephemeral Stream - A stream that typically has no well defined channel, and which flows only in direct response to precipitation with runoff. Fig. 3-3 shows a topographic map of the property with a solid "blue line" stream feature for Muckalee Creek as a perennial stream. The unnamed intermittent stream is a dashed “blue line”, evident on the 272-acre property from the center of the site and flows northeast as a tributary of Muckalee Creek. These streams are under USACE and Georgia Department of Natural Resources jurisdiction. The recent wetlands delineation on the property also surveyed the alignment of the unnamed intermittent stream (Lanier, 2008). About 2,255 linear feet of jurisdictional stream exists within the primary reach of the tributary originating within the central part of the site “blue-line” stream (TTL, 2009b). Fourteen additional stream segments are located within the site’s jurisdictional wetlands. These features total about 4,270 linear feet of jurisdictional channels. These jurisdictional aquatic features are protected by federal and state laws and regulations. Based on the fact that the site’s intermittent streambed starts at an elevation of 375 feet amsl, the estimated depth to groundwater below the proposed new hospital site (about 410 to 430 feet amsl) is usually from about 25 to about 35 feet below the ground surface. The groundwater flow direction is likely towards the northeast to Muckalee Creek. 3.3 Human Environment 3.3.1 Land Use and Zoning Land Use Around Former Hospital Site Use of properties around the Former Hospital site is discussed in geographic relation to the site; north, east, south, and west. North The site is bound to the north-northwest by Oglethorpe Drive and residential properties. East Jefferson Street, which formerly transected the northern part of this property east/west, is now north of the property. Properties along the north side of East Jefferson Street are now occupied by office trailers leased to the SRH Human Resources Department. The 3+/- acre parcel directly to the north along the west side has been developed with a residential structure (Wheatley House) since the 1920s, and is now used for PSMC executive offices. East The site is bound to the East by Mayo Street. The east adjacent property at the North Mayo Street/East Forsyth Street intersection has a CVS drugstore. Four office trailers, occupied by SRH staff, are stationed within an asphalt-paved parking area just north of the CVS along the east side North Mayo Street. The 80,000 square feet interim hospital building is just east of the SRH office trailers. South The site is bound to the south by East Forsyth Street. Walgreens and Taco Bell are south of the site, at the East Forsyth Street/North Mayo Street intersection. Reese Street intersects East Forsyth Street just south of the former hospital entrance. A 2-story house and undeveloped lots are along the southeast side of the intersection and a dermatology clinic is along the west side of the intersection. West The west adjacent property along the north side of East Forsyth Street has a 2,000 square feet dental office. Residential properties are north of the dental office, along the west side of Oglethorpe Avenue. Review of Former Hospital Site Historic Aerial Photos Nine (9) aerial photos of the Former Hospital site and surrounding area are available from 1937, 1948, 1953, 1962, 1968, 1972, 1988, 1993, and 2005 (Appen. A). 1937 The site is undeveloped land mostly cleared throughout the central part and wooded around the margins. Properties to the east and south are mostly undeveloped. Residential properties are to the north along the north side of Oglethorpe Avenue. 1948 Four or five structures, all apparently less than 3,000 square feet, are in the site’s the northeast area. According to interviews, these structures were likely associated with a former construction company, Americus Engineering and Construction, owned and operated by the former property owner, Mr. Wheatley. A small structure is shown at the property’s northwest corner just south of Oglethorpe Avenue. No other structures or improvements were noted on site. Six to eight apparent residential structures are east of the site and four or five small structures are south of the site. Two to three additional residential structures are shown north of the site, along Oglethorpe Avenue. 1953 The Sumter Regional Hospital building is shown on the central and western portions of the site. The building is accessed by a driveway extending north from East Forsyth Street. A parking lot is adjacent to and northeast of the building. The site’s northeast section appears wooded and the former construction company structures are scattered throughout this area. Surrounding properties’ appearance changed little from the 1948 aerial photo. 1962 The site or surrounding properties changed little from the 1953 aerial photo. 1968 Additional parking area east of the hospital. No other significant changes on the site or surrounding properties were noted from 1962 aerial photo. 1975 Hospital addition was built on its northeast side and additional parking area east of the hospital. Small paved area along the site’s northwest margin, just south of Oglethorpe Avenue. Appears to correspond with the former electrical transformer pad area observed during site reconnaissance. The site’s northeast part remains mostly wooded and occupied by the former construction company. 1988 No significant changes on the site from the 1974 aerial photo. Increased commercial development on the south and east adjacent properties. A new, large commercial structure is about 200 feet east of the site, and according to interviews, it was occupied by Wal-Mart. Additional commercial structures are at the East Forsyth and Mayo Streets intersection. 1993 No significant changes were noted on the site or surrounding properties from the 1988 aerial photograph. 2005 Asphalt parking lot addition along the hospital building’s east side and the site’s northeast portion (formerly occupied by the construction company). A large paved parking area and several office trailers are on the east adjacent property and the SRH Healthplex Annex building is slightly further east, within the former Wal-Mart footprint. The current CVS drugstore is also east of the site, at the intersection of Mayo and East Forsyth Streets. Review of Former Hospital Site Historic Sanborn Fire Insurance Maps Historic Sanborn fire insurance maps dated 1924, 1948, 1960, and 1963 (Append. A) were reviewed for the Former Hospital site to determine past land uses and/or structures on the site and adjacent properties (TTL, 2009c). Summarized: 1924 A house and a small out-building are shown at the southeast corner of the subject property at the intersection of East Forsyth Street and North Mayo Street. A general storage building, about 2,000 square feet area, is shown along the northern property margin just south of Oglethorpe Avenue. A small store is shown north of the subject property at the intersection of Oglethorpe and East Jefferson Street. All other surrounding properties are shown to be residential. 1948 The house and a small out-building are no longer appear in the site southeast corner. A symbol representing a gas tank is shown at the southeast corner of the storage building north-center of this site along Oglethorpe Avenue. Three other storage buildings are shown on the northeast portion of the subject property. A store with a gas tank symbol is shown on the east adjacent property at the northeast corner of East Forsyth Street and North Mayo Street. No other changes were noted from the previous map. 1960 The Sumter Regional Hospital building is shown within the west-central portion of the subject property. The western portion of the building is one story and the eastern portion is shown to be three-story. A laundry room is shown within the northern portion and a parking area is shown directly north of the building. An air-conditioning plant is shown within the northern portion of the building. No UST symbols were noted around the hospital building. Two stores are shown on properties adjacent to the south. No other significant changes were noted from the previous map. 1963 No significant changes were noted in the 1963 map from the previous map reviewed. Sanborn maps dated 1948, 1960, and 1963 show a gas tank symbol adjacent to a former storage building on the north-central portion of the subject property. The tank was likely associated with the former construction company owned and operated by the former property owner, Mr. Wheatley. The 1963 map shows the gas tank with a line crossing through it, suggesting it no longer existed or missing. A nearby small building to the west of the tank about 50 feet is also lined out reflecting it also is missing. Land Use Around New Hospital Site Use of properties around the new Hospital site is discussed in geographic relation to the site; north, east, south, and west. North Property north of the 272-acre property is owned by the Odum Family. Access to this property is off Odum Road on the northwest along the west side of the 272-acre property. The Odum property is used residentially and for aquaculture, i.e. catfish farm. East Muckalee Creek is on the 272-acre property’s northeast boundary. Properties east of Muckalee Creek are privately owned and generally undeveloped and wooded. A broad floodplain wetland is along on the east side of Muckalee Creek. Further east, about 1000 feet from the site, a residential area extends along Westside Drive. South Commercial and retail land use is present along the southeast boundary of the site at the intersection of US280 and US19. In the immediate northwest corner of this intersection is an Exxon gasoline station. North of the gasoline station is Granny's Kitchen, a restaurant; and, further north is an undeveloped parcel of land. A section of the subject site fronts US280/19 here and is currently leased by Alexander Construction Company as a construction field office for road work underway on US19 south of Americus. Alexander Construction Company currently has two office trailers on-site, along with a small barn and one aboveground storage tank containing diesel fuel. This leased area is adjacent to the Waffle House restaurant (not a part of 272-acre property). Northeast of the Waffle House restaurant is a Quality Inn hotel, and northeast of the Quality Inn hotel is a used car lot. On the southeast side of US19, in the northeast corner of the intersection with US280 is an abandoned Carl Gregory car sales office and lot. South of this property, on the south side of US280 is an approximately 3-acre garden. In the southwest corner of the intersection of US19 and US280 is a construction site and Fox International Company, Inc., tractor sales. Directly south of the subject parcel of land, across US280, is a TransMontaigne petroleum fuel storage terminal. This facility is also referred to as Southeast Terminal. West West of the site is northwest-trending McMath Mill Road, which intersects US280. Odum Road splits north off McMath Mill Road about 0.25 miles north of the US280/ McMath Mill Road intersection. Properties along these roads are undeveloped, residential, or agricultural. Review of 272-Acre Property Historic Aerial Photos Nine (9) aerial photographs of the 272-acre property and surrounding areas are from 1937, 1941, 1948, 1953, 1962, 1968, 1972, 1988 and 2005 (Appen. A). 1937 through 1953 - aerial photographs show the property in mostly agricultural. Pecan orchards are in the property’s southeast and northwest corners. A farmstead is in the property’s southeast corner north of an orchard. A second farmstead is near the northeast corner of McMath Mill Road and US280. A single building or barn is present near the center of the property. Heavily wooded "wetlands" are evident along Muckalee Creek, and along the unnamed tributary draining northeast to Muckalee Creek from the center of the site. Surrounding properties appear undeveloped and wooded, or in use agriculturally. 1962 - the property has a "young" stand of planted trees throughout the areas that were formerly in use agriculturally. A mature pecan orchard is in the site’s southeast corner, farmsteads are visible, along with a "barn" near the site’s center. Land uses around the site show little change. 1968 through 2005 - the property appears much as it is today. Planted pines are in many areas that are not orchard or wetlands. Most surrounding land uses appear little changed until the 1972 image, when the Quality Inn hotel is apparent. Other commercial development is evident in later years, near US19/US280 intersection. Review of New Hospital Site Historic Aerial Photos Nine (9) aerial photographs of the 45-acre New Hospital site are from 1937, 1941, 1948, 1953, 1962, 1968, 1972, 1988 and 2005 (Appen. A). The pecan orchard located on the south third of the site was evident in historical aerial photographs over 71 years, from 1937 to present. It does not appear the orchard has been used over the last 20 years. Farming was conducted on the north two-thirds of the site from 1937 up to the mid-1960s. The 1968 aerial photograph and later photographs show the site was not used for farming and the area reverted to secondary growth woodlands over the last 41 years. 272-Acre Property General Setting The 272-acre property is on a knoll top, a geographically high point, with nearby stream tributaries flowing away to the east, southeast (south of US280), west, and northwest. The property is wooded with old pecan orchards located in the northwest and southeast corners. Unimproved roads or trails transect the property from north to south and from west to east. Access to the interior of the property is via these trails. In general, the property slopes from a point in the southeast corner, to the south-southwest in the direction of an unnamed intermittent stream tributary of Muckalee Creek (south of US280), and toward the east-northeast in the direction of Muckalee Creek. The northeast corner of the property is largely comprised of floodplain of Muckalee Creek. Other areas throughout the interior of the property are wooded uplands; and two utility easements transect the property. New Hospital Site General Setting The New Hospital site is on the geographically high southeast hill on the 272-acre property. Drainage at the site is radially away from the hilltop. The south third of the site contains a +70 year old pecan orchard. The site’s north two thirds area has secondary growth woodlands that are at least 41 years old. The maintained dirt road for the TransMontaigne oil pipeline easement is on the west side of the site. US280 lies to the south. US280/US19 lie to the southeast. Other secondary growth woodlands lie to the northeast and north of the site, beyond which lies Muckalee Creek wetlands and tributary streambeds. The maintained dirt road for the City of Americus water, sewer and natural gas utility easements pass through the site just north of the old pecan orchard. 272-Acre Property Existing Building Observations (Interior) Two temporary structures, a construction site trailer and a pole-barn storage shed in the site’s southeast corner, are leased by Alexander Construction Company as a construction office. The on-site office trailer has temporary office equipment typical of a construction site. No other buildings are located on the subject property. No buildings are evident on the 45-acre proposed New Hospital site. 3.3.2 Demographics and Housing The following description of demographics and housing for the City of Americus, Georgia, is from Wikipedia (2009). As of the 2000 census, there were 17,013 people, 6,374 households, and 4,149 families residing in the city. The population density was 1,623.1 people per square mile. There were 7,053 housing units at an average density of 672.9 per square mile. Of 6,374 households, 32.8% had children under age 18 living with them, 34.2% were married couples living together, 27.4% were female single-head of household, and 34.9% were non-families. 29.6% of households were of individuals, 10.5% had someone living alone who were age 65 or over. Mean average household size was 2.52, and mean average family size was 3.14. The city the population was 28.0% under age 18, 14.1% age 18 to 24, 26.1% age 25 to 44, 18.0% age 45 to 64, and 13.7% age 65 or over. Median age was 30 years. For every 100 females, there were 79.4 males. For every 100 females age 18 and over, there were 70.4 males. Median city household income was $26,808, and median family income was $32,132. Median income was $27,055 for males and $20,169 for females. Per capita income was $14,168. About 23.4% of families and 27.7% of the total population were below the poverty line, including 44.1% of those under age 18 and 19.8% of those age 65 or over. Races in Americus (City-Data, 2009): * African-American (58.3%) * White Non-Hispanic (38.0%) * Hispanic (2.5%) * Other race (0.9%) * Two or more races (0.7%) * Native American (0.5%) The 2000 U.S. census data shows Sumter County and its communities have a disproportionately large segment of households in the lowest of household income levels. The U.S. Department of Housing and Urban Development (HUD) defines low and very low-income limits, respectively, as at or below 80 percent and at or below 50 percent of median income for an area (HUD, 2009). Sumter County as a whole shows that 17.5% of the households make less than $10,000 annually. Americus has the highest number of households that make less than $10,000 annually with 22%. In 2007 Americus had a median household income of $30,138. The Georgia median household income was $49,136 (City-Data, 2009). The 2008 cost of living index in Americus: 79.0 (low, U.S. average is 100) (City-Data, 2009) The Sumter County Joint Comprehensive Plan third 5-year update includes a survey of low and moderate income minority neighborhoods in Americus (Sumter, 2009). Neighborhood surveys are done about every 2 years for government grant applications. The neighborhood character has remained essentially the same since the surveys began to be documented in the first county comprehensive plan completed in 1994 (Rigsby, 2009). Fig. 3-8 shows the map from this study outlining the city boundaries, except for part of the southern area with no identified neighborhoods. Shaded areas are outlined which identify the poorer neighborhoods. These are located generally in the north part of the city. The locations of the Former Hospital and the New Hospital are included on the figure. The upper left corner of Fig. 3-8 is a census tract map from the 2000 U.S. census that shows the percent of minority African-Americans in the 5 tracts. 3.3.3 Local Economy and Employment The City’s economy is based primarily on healthcare, higher education institutions, small commercial and industrial enterprises, and local government. The city government payroll included 159 full-time employees and 14 part-time employees at a total annual cost of $5.1 million for salaries and wages. Sumter County total annual cost is $5.4 million for salaries and wages (City-Data, 2009). Many county employees likely live in Americus and contribute to the local economy. Americus is hometown for Habitat for Humanity International's international headquarters, Windsor Hotel, Fuller Center for Housing international headquarters, and Glover Foods. Habitat for Humanity a non-profit organization dedicated to eliminating substandard housing around the world is well known for providing housing opportunities for low-income families. It is now one of the top ten homebuilders in the country. In 2009 Home Depot pledged $30 million over the next five years to ensure that 5,000 new homes built by Habitat for Humanity will comply with environmental initiatives such as “Energy Star” and “LEED” (Habitat, 2009). This may attract modern “green” building designers to work for and with Habitat for Humanity in Americus. The healthcare industry is a major employer for the City of Americus and Sumter County. This includes the Sumter Regional Hospital/Phoebe Sumter Medical Center and associated healthcare businesses. As of August 2009, SRH has a roster of 134 physicians available and credentialed to access use of SRH facilities. The income generated in the community by the physicians alone is estimated at $138 million. This is based on an economic impact survey of a family physician in Georgia estimated to be $1,028,774 per doctor per year (Graham, 2007). This excludes specialty physicians that may have higher economic impacts. This also does not include income to hospitals or to nursing homes. Figure 3-8 is a map of the areas with low-income and minority populations in Ameicus, Georgia. Higher education institutions in the City of Americus depend upon good local healthcare services being available to attract and retain students, faculty and staff. Noted institutions include the following (City-Data, 2009): Georgia Southwestern State University – Full-time enrollment 1,967 (offers Master’s degree) – 1.5 miles southeast of city center. South Georgia Technical College – Full-time enrollment 896 – 5 miles northeast of city center. The City of Americus, compared to Georgia state averages, was compiled by developers of a web site using U.S. Census data and a network of other economic and employment data sources (City-Data.Com, 2009): The following bullets summarize points for the City of Americus, Georgia: * Median household income below state average. * Median house value significantly below state average. * Black race population percentage significantly above state average. * Hispanic race population percentage significantly below state average. * Median age below state average. * Foreign-born population percentage significantly below state average. * Poverty rate among disabled males: Americus 20 % Georgia 15.4 % * Disability rate in this city among poor males (it is 24.7% among residents who are not classified as poor): Americus 23 % Georgia 15.4 % * Poverty rate among disabled females: Americus 33.3 % Georgia 21.4 % * Disability rate in this city among poor females (it is 24.3% among residents who are not classified as poor): Americus 29 % Georgia 21.4 % * Renting rate in this city among poor and not poor residents: Americus 74.4 % Georgia 40.3 % Most common occupations for males (percent) * Other production occupations including supervisors (7%) * Material moving workers except laborers and material movers, hand (5%) * Laborers and material movers, hand (5%) * Law enforcement workers including supervisors (4%) * Building and grounds cleaning and maintenance occupations (4%) * Driver/sales workers and truck drivers (4%) * Material recording, scheduling, dispatching, and distributing workers (4%) Most common occupations for females (percent) * Preschool, kindergarten, elementary and middle school teachers (7%) * Nursing, psychiatric, and home health aides (5%) * Building and grounds cleaning and maintenance occupations (5%) * Cashiers (5%) * Health technologists and technicians (4%) * Registered nurses (4%) * Counselors, social workers, and other community and social service specialists (4%) The above occupations listed for females reflect the employment opportunities dependent upon the local SRH hospital facilities. 3.3.4 Community Facilities and Services The Americus Police Department headquarters are on Lee Street near Lamar Street. The headquarters for the Americus Fire Department, Station No. 1, are also on Lee Street near Lamar Street. Station No. 2 is located off Southfield Road near the airport, about 5 miles northeast from the city center. Station No. 3 is located on Crawford road about 1.5 miles northeast of the city center. These stations protect the 11.4 square miles comprising the City of Americus, as well as an additional 160 square miles of unincorporated area through a contract with Sumter County (Americus, 2009). The temporary hospital, SRH East, comprises the healthcare facilities available to residents of the City of Americus. This hospital facility does not reach the level of healthcare of the SRH Former Hospital. Based on SHR records, the number of inpatient days at the Former Hospital for five months before the March 2007 disaster averaged 1726 per month (Halford, 2009). For six months after the SRH East temporary hospital opened in April 2008, the number of inpatient days averaged 1017, or 59 percent of the use of the Former Hospital. A review of admission records from before the March 2007 disaster, for the months of January and February 2007, indicate 72 percent of the patients were from Sumter County. A total of 11 percent were from Macon County, 8 percent from Schley County, and the remaining 9 percent came from Crisp, Dooly, Marion, Stewart and Webster counties (Halford, 2009). A review of admission records from the month of July 2009 indicate 84 percent of the patients were from Sumter County (Halford, 2009). A total of 5 percent were from Macon County, 3 percent from Schley County, 3 percent from Marion County, and the remaining 5 percent were from Crisp, Dooly, Taylor, Lee and Houston counties. It does appear residents in Sumter County and the surrounding counties are getting their healthcare at other locations. Other hospitals/medical centers near Americus include the following: * Flint River Community Hospital (about 19 miles; Montezuma, GA) * Stewart Webster Hospital (about 25 miles; Richland, GA) * Crisp Regional Hospital (about 27 miles; Cordele, GA) * Palmyra Medical Center (about 32 miles; Albany, GA) * Phoebe Putney Memorial Hospital (about 34 miles; Albany, GA) * Columbus Regional Healthcare System hospitals (about 60 miles, Columbus, GA) * Medical Center of Central Georgia hospitals (about 75 miles, Macon, GA) Americus residents who require a range of services or specialty health care needs are likely to go to Phoebe Putney Memorial Hospital, in Albany, or go a greater distance to Macon, where there are more and a broader range services available. Albany is 4.6 and Macon is 6 times larger in population than Americus (U.S. Census, 2009). Community recreational facilities in the City include a total of 24 small parks and 3 public swimming pools (Butcher, 2009). A map of these facilities show they generally lie between the Former Hospital site and the New Hospital site. 3.3.5 Environmental Justice Presidential Executive Order 12898 requires Federal agencies to make achieving environmental justice part of their mission by identifying and addressing disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority and low-income populations. EO 12898 also tasks Federal agencies to ensure that public notices about environmental issues are concise, understandable, and readily accessible. Taken together the Former Hospital site and the New Hospital site within the city boundaries are about equal in relative distance and time to the identified low-income minority neighborhoods. The Former Hospital site lies to the southeast of the main low-income minority neighborhoods within the congested east side of the city with slower traffic and more traffic signals. The New Hospital site lies to the southwest of these neighborhoods where there is faster traffic and fewer traffic signals. On average low-income minority patients in the city using a hospital at either location would drive or be driven by private or public transportation to the site in essentially the same amount of time. 3.3.6 Noise Noise levels at the Former Hospital site and the New Hospital site are expected to be about the same. The Former Hospital site is next to East Forsyth Street, also known as westbound US280. The New Hospital site is next to US280. Vehicular traffic is the primary noise source for both sites 3.3.7 Visual Resources The City sights range from a busy small urban community to a quiet rural community rich in vegetation and heritage. The area around the Former Hospital site consists of quite, established neighborhoods, of one-story single-family homes and small commercial businesses. The area around the New Hospital site consists of a quieter rural neighborhood with farming and some moderate-sized commercial and industrial businesses. The planned hospital is to be located within and surrounded by the an existing forest. 3.4 Cultural Resources In addition to NEPA review, consideration of impacts to cultural resources (archaeological and historic sites and structures) are mandated under National Historic Preservation Act (NHPA) Section 106 as implemented under 36 CRF Part 800. Requirements include the need to identify significant historical properties that may be impacted by the proposed action (also known as “undertaking”) or alternatives. Historic properties are defined as those listed on or determined eligible for listing on the National Register of Historic Places (NRHP) (36 CFR 60.4). The Georgia State Historic Preservation Officer (GA SHPO) and FEMA consult to determine site eligibility, and the Keeper of the National Register makes final determinations. GA SHPO and the Advisory Council on Historic Preservation (ACHP) must be consulted on impacts to significant resources and means to mitigate the impact. Consultation procedures and impact mitigation are outlined in the project-specific Programmatic Agreement (PA) signed by FEMA, GA SHPO, and ACHP. Compliance with NHPA Section 106 will be addressed through the PA execution. The PA serves as guidance for FEMA in their consultation with GA SHPO, ACHP, and other relevant agencies. It addresses potential impacts to historic structures and archaeological sites, and mitigation measures. 3.4.1 Historic Structures National Register of Historic Places (NRHP) Review of the NRHP National Register Information System (NRIS) was done to determine if the site was already in the NRHP. The NRHP NRIS is a publicly available database provided by the Department of Interior, National Park Service at http://nrhp.focus.nps.gov/natreg/docs/Download.html (USDOI, 2009). Results for Former Hospital Site Review of the NRHP NRIS indicated the Former Hospital site is not in the NRHP. The nearest NRHP sites are about 1/4 mile west and south of the New Hospital site, in Historic Downtown Americus. As the Former Hospital was destroyed and the site buildings demolished and cleared, there are now no historical structures on the site. Results for New Hospital Site Review of the NRHP NRIS indicated that the subject property is not in the NRHP. The nearest NRHP sites are about 1 mile east of the New Hospital site, in Historic Downtown Americus. The Phase I Archaeological survey results indicate that the 45-acre New Hospital site has low probability for occurrence of archaeological sites that might be considered eligible for NRHP listing (Perry, 2009 and Appen. C). The single identified archaeological site, Provisional Site 1, was occupied with a small house from about 1937 to 1972, based on aerial photographs. It was not evident on the 1988 photograph. Based on literature and documents review interpretation and evaluation and field reconnaissance, Provisional Site 1 does not meet the eligibility requirements of any of the criteria for inclusion on the NRHP, per 36 CFR § 60.4. In particular, Criterion D is unlikely to be met due to the modernity of the site occupation, the sparse cultural materials present, and severe disturbance by mechanized clearing in the late 20th century. Therefore, it is recommended that Provisional Site 1 is not eligible for the NRHP. The 45-acre proposed New Hospital site has low probability for archaeological sites that might be considered eligible for NRHP listing. As a result of late 20th century land management practices, the entire tract appears to have been severely disturbed. During the 19th and early 20th century agricultural uses of the property, upland soils eroded from the subject property to the area to the north and in the late 20th century, when mechanized clearing was done, any remaining cultural deposits were likely disturbed (Perry, 2009). 3.4.2 Archaeology Georgia Archaeological Site File (GASF) A GASF review was done to determine if the site had been previously surveyed, or if previously identified sites had been report on the site (Perry, 2009). Since GASF provides all Georgia data for the NADB, the GASF review also constituted a NADB review. The GASF database is restricted to professional archaeologists to protect sensitive known archaeological site information from entering the public domain. Results GASF review indicated that the site had not been part of a previous archaeological survey and no archaeological sites have been recorded within the property boundary. Two archaeological sites were recorded within a 0.5 mile radius of the subject property, from the DOT US19 road widening project’s archaeological survey. Field reconnaissance results include one previously identified historic archaeological/ farmstead site and six isolated finds, single artifacts (Perry 2009). Based on the field reconnaissance observations and literature and documents review, the previously unidentified archaeological/farmstead site’s, Provisional Site 1, boundaries were established (Fig. 3-9). The archaeological/farmstead site consists of a small scatter of historic materials from the early 20th century to before 1988. Provisional Site 1 surface features include a small brick pile and domesticated plants. Figure 3-9 shows the results of the archaeologic surveys conducted on the proposed 45-acre site for the New Hospital. The 272-acre property was agriculturally abandoned after the 1960s, and was mostly timbered by the late 1980s to early 1990s. Mechanized land clearing in the late 20th century appears to have severely impacted the property’s historic integrity. The land use at the 45-acre New Hospital site did not change since at least before 1968, over 41 years ago.  The 1968, 1972, 1988, 1999 to present aerial photos show a continuous regrowth of natural woodland on the north two-thirds of the site. The pecan orchard on the south has been there since 1937, over 72 years. Phase I Cultural Resources Reconnaissance results indicate the 45-acre proposed New Hospital site has low probability for archaeological sites that might be considered eligible for NRHP listing. The single identified archaeological site, Provisional Site 1, was occupied well no later than 1988. 3.5 Infrastructure 3.5.1 Water Supply The Americus water is from a set of 11 deep groundwater wells located throughout the city. Older wells pump groundwater found at depths as great as 800 feet. The Georgia DNR Environmental Protection Division (EPD) monitors the operations of the Americus wells and now permits new water supply wells that reach depths of 1800 to 2000 below ground surface. EDP wants to avoid potential shallow groundwater contamination and also to avoid pumping interferences with the local farmers pumping groundwater (Campbell, 2009). Americus has “North” and “South” ground water supply treatment plants for their 11 wells. Treatment only involves removal of iron and addition of chlorine gas as a residual disinfectant. Former Hospital Site The City of Americus Public Works Department (DPW) provided water to the site as the local public water supplier. The Americus water is from a set of 11 deep groundwater wells located throughout the city. Older wells pump groundwater found at depths as great as 800 feet. The Georgia DNR Environmental Protection Division (EPD) monitors the operation of the Americus wells and now permits new water supply wells that reach depths of 1800 to 2000 below ground surface. DHS wants to avoid potential shallow groundwater contamination and also to avoid pumping interferences with the local farmers pumping groundwater (Campbell, 2009). New Hospital Site The Americus DWP plans to provide water to the hospital site. Americus has an east-west utility easement that passes through the southern third 45-acres hospital site. It contains both a 10-inch diameter water supply transmission pipeline and a force main sewer pipeline, that presently service the Sumter County Jail and law enforcement facilities further west of the New Hospital site. 3.5.2 Wastewater Disposal Sanitary sewer service is provided by the Americus PWD for nearly all of the developed areas in Americus. Wastewater flows are collected in gravity sewers and conveyed to lift stations which transport the flow to the south treatment plant located 2.5 miles south of Americus along Muckalee Creek. The Former Hospital site had sewer lines which have been capped after the buildings were demolished. The New Hospital site, as mentioned in Section 3.5.1 regarding water supplies, has an Americus PWD water, sewer and natural gas easement for pipelines that presently service the Sumter County Jail and law enforcement facilities on the west. There is adequate capacity in the utilities to accommodate the needs of the New Hospital (Kendrick, 2009 and Deason, 2009). 3.5.3 Other Public Utilities Other utilities considered include telephone, electric, and natural gas service. Telephone service is provided to the City of Americus area by Southern Bell or AT&T. Electrical power is provide by Georgia Power. Natural gas service is provided to the community by the City of Americus Natural Gas Services Department (Deason, 2009). These services were cut off to the Former Hospital site following the 2007 disaster and are available at or nearby the proposed New Hospital site. Prior to any site construction, the site will be examined for existing utility lines. If utility lines are found, officials from the utilities should be notified before any ground is disturbed. 3.5.4 Transportation The City of Americus Transit System includes the use of four on-call vans that can transport passengers around the community at a flat cost of $2.00 per ride. The Americus Community and Economic Development Department manages the Transit System and reported an annual average of 90 rides per day over the last 4 years, 2006 to 2009 (Young, 2009). Two private taxi companies also exist in the city that can transport passengers at a flat cost of $5.00 per ride. Transportation within Americus is done mostly by private vehicles, secondarily by walking. Table 3-5 summarizes the commuting to work statistics compiled by the U.S. Census Bureau (2009). This shows 94.5 percent of the residents typically drive, 3.3 percent walk, and 2.2 percent travel to work by other means.Table 3-5: Americus, Georgia – Commuting to Work Statistics (2000) Workers 16 years and over 6,604 Percent Car, truck, or van -- drove alone 4,990 75.6 Car, truck, or van -- carpooled 1,248 18.9 Public transportation (including taxicab) 23 0.3 Walked 215 3.3 Other means 73 1.1 Worked at home 55 0.8 Mean travel time to work (minutes) 16.0 (X) Former Hospital Site The main access to the Former Hospital site and parking areas was through Mayo Street (See Fig. 3-1). A secondary services access road was at the southwest corner of the site on East Forsyth Street. The hospital emergency entrance was north of the hospital along Oglethorpe Street at the intersection of East Jefferson Street. All streets surrounding the site are two-lane, two-way commercial and residential roads, with a speed limit of 25 to 35 miles per hour (mph). East Forsyth Street (part of US280) is a one-way three-lane west-bound road along the south side of the site. It has a speed limit of 35 mph near the Former Hospital and decreases to 25 mph as it passes through historical downtown Americus. Traffic signals are at the two main intersections with access to the site on Mayo Street, on the north at Oglethorpe Street and on the south at East Forsyth Street. A sidewalk exists only along Mayo Street. New Hospital Site The New Hospital site is located just north of the intersection of and traffic signal for US19 and US280. At this location both highways have 5 lanes, 2-lanes each direction with a painted median/turning lane, with 55 mph speed limits. US19, also known as N. Martin Luther King, Jr. Blvd., traverses Georgia north-south. US280 generally goes eastwest across the state. Both highways merge from this location northeastward 4000 feet to W. Forsyth Street/W. Lamar Street. There, US19 continues northeast and US280 continues east. There are two traffic signals here, one at the Magnolia Street intersection, and another 300-feet north as US280 becomes a divided road, using West Forsyth Street for west-bound traffic and W. Lamar Street for east-bound traffic through the city center. The main access to the New Hospital site and parking areas is planned to be through a north-south 4-lane driveway on the south along US280, about 1000 feet west of its intersection with US19 (Fig. 1-7). A new traffic signal is proposed at the main hospital entrance for traffic safety of hospital patients, visitors and staff. A secondary 2-lane access driveway is planned to the hospital parking area on the east, at an entrance off US19, about 500 feet from its intersection with US280. The New Hospital site has plans for sidewalks along the highways. Traffic control is at a traffic signal at the US19/US280 intersection, near the New Hospital site’s southeast corner. Both U.S. Highways merge from this location northeastward 4000 feet up to W. Forsyth Street/W. Lamar Street. Here, US19 continues northeast and US280 continues east. There are two traffic signals near here as US280 becomes a divided road. One signal at Magnolia Street and one located 500 feet further northeast to manage traffic for US280 through the center of Americus, West Forsyth Street west-bound traffic and West Lamar Street east-bound traffic. Major roadway improvements to US19 are presently being completed by GA DOT. This involves widening the road to 5 lanes, 2-lanes each direction with a painted median/turning lane. In July 2009 new concrete curb and gutter roadway details were completed from the US19/US280 intersection/merge on the north side of the road up to the southeast corner of a used car dealership, located southeast of the 272-acre property. DOT plans to complete construction of a concrete sidewalk from the US19/US280 intersection/merge to the used car dealership driveway. The new north-side highway bridge widening across Muckalee Creek includes a simple 3-feet high concrete barrier/rail and is not designed for a sidewalk. The south side of the highway bridge presently has the older/original sidewalk and rail across Muckalee Creek. The City plans to build a new sidewalk along the N. Martin Luther King, Jr. Blvd. easement, towards the New Hospital site. Following present GA DOT work, it will tie in with the city existing sidewalk network that now end at the intersections of W. Forsyth Street/W. Lamar Street and N. Martin Luther King Jr. Blvd. The New Hospital site is further than the Former Hospital site, respectively, 1.3 miles versus 0.6 mile, from the city center. However, the time needed to get to each site is about the same, because the city’s east side has more traffic signals and slower traffic speeds than those on the city’s west side. Emergency transportation arrangements have been made for the new hospital site in case the US19/US280 bridge is impassable, damaged, or destroyed because of flooding, a vehicle accident, or other event. Specifically, the first alternative transportation route is the Church Street/Spring Street Muckalee Creek bridge, located 1000 feet south/downstream of and parallel to the US19/US280 bridge. The second alternative route is the Georgia State Route 30 Muckalee Creek bridge, located 5000 feet north/upstream. It is anticipated the potentially damaged 300-foot span of the key regional US19/US280 bridge crossing Muckalee Creek would be repaired quickly as a high priority federal highway construction project following a flooding event. …[+r2] 3.6 Hazardous Waste and Materials A Phase I Environmental Site Assessment (ESA) was conducted at the Former Hospital site and the New Hospital site by qualified environmental scientists (TTL, 2009b and 2009c). The objective of an ESA is to assess the presence of recognized environmental conditions that may exist as a result of past or present uses of the properties within the five proposed areas. The American Society for Testing and Materials (ASTM) Standard E-1527-05 defines a recognized environmental condition (REC) as: …the presence or likely presence of any hazardous substance or petroleum products on a property under conditions that indicate an existing release, a past release, or a material threat of a release of any hazardous substances or petroleum products into structure on the property or into the ground, groundwater or surface water of the property. Findings are based on information obtained through Federal and state databases, interview, and site reconnaissance. 3.6.1 Site Reconnaissance Site reconnaissance was conducted on the Former Hospital site and the 272-acre property. Following the March 1, 2007 tornado disaster event, all of the Former Hospital damaged buildings were demolished and cleared from the site. Presently, the asphalt parking lot on the east side of the 12.5 acre property remains intact, with about 20,000 cubic yards of crushed concrete debris and gravel in two piles remaining near the middle of the regraded west side of the property. The 272-acre property is presently characterized as a former farmland with a forest that has regrown over the last 50 years. As described above a couple of cleared dirt roads cross the 272-acre property as underground pipeline easements for private and public utilities. The north-south cleared dirt road easement is for crude oil to the TransMontaigne fuel storage facility south of the property. The east-west cleared dirt road easement is for the City of Americus water, sewer and natural gas pipelines that lead out to the Sumter County Jail and law enforcement facilities west of the property. 3.6.2 Former Hospital Site Conditions EPA National Priorities List (NPL) The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) established the Environmental Protection Agency (EPA) National Priorities List (NPL) of federal "superfund" sites. These are the contaminated sites that have been assigned a high ranking, in terms of potential public health effects, by the EPA. The EDR report indicates that: The subject site is not identified on the EPA NPL List. There were no facilities identified on the NPL within the AMSD of one mile of the subject property. EPA Delisted National Priorities List (Delisted NPL) The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) established the criteria that the EPA uses to delete sites from the NPL. In accordance with 40 CFR 300.425.(e), sites may be deleted from the NPL where no further response is appropriate. The EDR report reviewed indicates that: The subject site does not appear on the Delisted NPL. There were no facilities identified on the Delisted NPL within the AMSD of one-half mile of the subject property. EPA Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) List The EPA Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) List identifies documented and suspected contamination sites throughout the nation which were not ranked high enough to be listed on the NPL. The EDR report indicates that: The subject site does not appear on the CERCLlS List. There were no facilities identified on the CERCLIS List within the AMSD of one-half mile of the subject property. CERCLIS No Further Remedial Action Planned (NFRAP) List The CERCLIS-NFRAP is a listing of sites designated "No Further Remedial Action Planned" which have been removed from CERCLIS List. NFRAP sites may be sites where, after an initial investigation, no contamination was found, contamination was removed quickly without the need for the site to be placed on the NPL, or the contamination was not serious enough to require Federal Superfund action or NPL consideration. The EDR report indicates that: The subject site does not appear on the CERCLIS-NFRAP List. There were no facilities identified on the CERCLIS-NFRAP List within the AMSD of one-half mile of the subject property. Federal RCRA Corrective Action Report (CORRACTS) Facilities List RCRA is the EPA database of facilities that generate, transport, treat, store, and/or dispose of hazardous wastes as defined by the Resource Conservation and Recovery Act. CORRACTS identifies hazardous waste handlers with RCRA corrective action activity. The EDR report indicates that: The subject site does not appear on the RCW-CORFIACTS Facilities List. There were no facilities identified on the RCRA-CORRACTS List within the AMSD of one mile of the subject property. EPA Resource Conservation & Recovery Act Information (RCRA) List RCRA is the EPA database of facilities that generate, transport, treat, store, and/or dispose of hazardous wastes as defined by the Resource Conservation and Recovery Act (RCRA), Generators and transporters are found on the RCRA List of Generators/Notifiers. Conditionally Exempt Small Quantity Generators (CE-SQGs) generate less than 100 kilograms (kg) of hazardous waste, or less than I kg of acutely hazardous waste per month. Small Quantity Generators (SQGs) generate between 100 and 1,000 kg of hazardous waste per month. Non- Generators (Non-GEN) do not presently generate hazardous waste. Large Quantity Generators (LQGs) generate over 1,000 kg of hazardous waste, or over 'l kg of acutely hazardous waste per month. Transporters are individuals or entities that move hazardous waste off-site from the generator. This waste is transported to a Treatment, Storage, or Disposal Facility (TSDF). The ASTM standard states that the AMSD for SQGs, LQGs, and Non-GEN facilities is for the subject property and/or adjoining properties only. The ASTM standard defines an adjoining property as: "…any real property or properties the border of which is contiguous or partially contiguous with that of the property, or that would be contiguous or partially contiguous with that of the property but for a street, road, or other public thoroughfare separating them. " Conditionally Exempt - Small Quantity Generators (CE-SQG) The subject site does not appear on the RCRA- CE-SQG List facilities List. There were no facilities identified on the RCRA- CE-SQG List within the AMSD of 0.25-mile of the subject property. Small Quantify Generators (SQG) The Sumter Regional Hospital, formerly located on the subject property, is listed in EDR regulatory records as a RCRA-SQG site. Our review of the SQG listing information reveals that spent halogenated solvents were generated at the facility. A compliance visit was conducted on April 29, 2005 and no violations were reported. No reports of spills, releases, or violations otherwise were reported at the hospital. There were no facilities identified on the RCRA- SQG List within the AMSD of 0.25-mile of the subject property. Large Quantity Generators (LQG) The subject site does not appear on the RCRA-LQG List. No facilities were identified on the RCRA-LQG List within the AMSD of 0.25-mile of the subject property. Non-Generators (Non-GEN) The subject site does not appear on the RCRA Non-GEN List. Three (3) facilities were identified on the RCRA Non-GEN List within the AMSD of 0.25-mile of the subject property. However, none of the identified facilities are located contiguous to the subject property and no violations were reported at any of the RCRA Non-GEN facilities. U.S. Institutional Control (USIC) List The USIC List is a listing of sites with institutional controls in place. Institutional controls include administrative measures, such as groundwater use restrictions, construction restrictions, property use restrictions, and post remediation care requirements intended to prevent exposure to contaminants remaining on site. Deed restrictions are generally required as part of institutional controls. The ASTM standard states that the AMSD for the USIC List is limited to the subject property only. The EDR report indicates that: The subject property does not appear on the USIC List. State Landfill List The Georgia Environmental Protection Division (EPD) maintains a list of active and inactive landfills, artificial fills, and disposal sites. However, it should be noted that the Georgia EPD Landfill List does not include unpermitted landfills or dumps. The EDR report indicates that: The subject site does not appear on the Landfill List. There were no facilities identified on the State Landfill List within the AMSD of 0.50-mile of the subject property. State Hazardous Waste Sites (SHWS) List The Georgia State Hazardous Waste Sites (SHWS) List is equivalent to the Federal CERCLIS List and is maintained by the Georgia EPD. The EDR report indicates that: The subject property does not appear on the SHWS List. One SHWS listing, identified as the 304 North Dudley Street site, located greater than 0.50-mile west of the subject property. Due to the distance removed from the subject property and intervening topographic features, this SHWS listing is not considered to represent a recognized environmental condition likely to adversely impact the subject property. State Leaking Underground Storage Tank (LUST) List The Georgia EPD maintains a list of sites with reported Leaking Underground Storage Tanks (LUSTS) located within the state of Georgia. This list documents Underground Storage Tank (UST) systems that have reported releases of UST contents. Based on review of physical location information for each of the LUST sites noted on the EDR report, one of the identified LUST sites is located within the limits of the subject property. The site, identified as Americus Engineering and Construction (AEC) (Facility 1.D. 09129003), was formerly located at the northeast portion of the Former Hospital site. According to interviews, the AEC site was formerly owned and operated by the former owner of the subject property, Mr. Charles Wheatley Sr. Based on regulatory information reviewed, on December 4, of 1991 the Georgia EPD was notified of removal activities for a 500-gallon UST and a 2,000-gallon UST at the former construction company site. On December 9, 1991 a release was reported to the Georgia EPD. A closure report prepared and submitted to EPD in early 1992. On September 9, 1997, while performing site grading for the hospital building expansion project, east of the main hospital building, areas of petroleum-contaminated soil were found. The contaminated soil areas were found within the footprint of the former construction company site. On September 10 & 11, Geosciences, Inc. performed a test pit exploration and sampled soils based on field screening activities. Two (2) areas of soil contamination were identified and Geosciences personnel monitored the excavation and stockpiling of contaminated soil. Stockpiled soils were sampled and tested by Geosciences to determine if the soil material was hazardous or non-hazardous prior to disposal. All stockpiled soil (1,000 tons) was disposed as contaminated non-hazardous waste at ReNew Earth Recovery Systems in Macon on Sept 15-18, 1997. The scope of work did not include evaluation of the extent of contaminated soils outside the footprint of the proposed excavation. Based on discussions with Scott Frazier of EPD, confirmation sampling of excavation bottom and sidewalls was not required (TTL, 2009c). Following a technical review of the report, a "no further action" (NFA) letter was issued for the site by the EPD on July 31 1998. Interviews with EPD confirm the information presented by EDR. A copy of the "no further action" letter is included in Appendix B. A total of seven fuel storage tanks were identified by records and interviews to have been located on the Former Hospital site (Fig. 3-10). Tank 1 - AEC Gasoline tank – first noted on 1948 Sanborn map next to a one-story general storage building likely associated with AEC activities. The building existed at north-center of site since at least 1924. On 1963 Sanborn map the tank has a line drawn through it indicating it was removed or abandoned in place. During excavation for the hospital building expansion in 1997 this tank was not discovered (Wisham, 2009). This suggests it was removed from this location between 1960 and 1963. It is unknown if this tank contributed to the contaminated soils discovered during the 1997 excavation. This tank represents a historic recognized environmental condition (REC). Tanks 2 & 3- AEC Diesel tanks – two tanks with capacities of 500 and 2000 gallons which were removed in December 1991. A release was reported to EPD on December 9, 1991 and a closure report prepared early in 1992. On July 31, 1998, a “no further action” (NFA) letter was issued for the AEC LUST site. The approximate location of these two tanks is identified on Fig. 3-10 at the east-northeast edge of the 1997 excavation for the hospital building expansion (Wisham, 2009). As stated above a total of 1,000 tons of diesel-contaminated non-hazardous waste soils were removed for treatment and disposal off site. Based on witness field observations, the approximate lateral extent of the contaminated soil found is shown on this figure covering about 50 percent of the excavation area on the northeast. These tanks and related contaminated soils represent a historic recognized environmental condition (REC). Tank 4 - SRH No. 2 Diesel 3,000 gallon tank for the hospital emergency generator, located near the hospital emergency room entrance along Oglethorpe Street near E. Jefferson Street, was filled with concrete in 1998. It was replaced with a 6,000 gallon tank as an upgrade to capacity for emergency generator needs that included the 1998 hospital building addition. The 3,000 gallon tank filled with concrete was excavated and removed from the site February 2008, as part of the site demolition activities following the March 2007 disaster (Wisham, 2009). Tank 5 - SRH No. 2 Diesel 6,000 gallon replacement tank for upgraded hospital emergency generator, located along Oglethorpe Street about 50 feet northeast of the former 3,000 gallon tank filled with concrete in 1998 (Wisham, 2009). This tank was excavated and removed from the site February 2008, through site demolition activities (Wisham, 2009). Tank 6 - SRH No. 5 Heating Oil 10,000 gallon tank for the hospital boiler, located along Oglethorpe Street on east side of the hospital loading docks (Wisham, 2009). It was removed in 1998 and replaced with a larger double-walled tank in compliance with UST regulations. Tank 7 - SRH No. 5 Heating Oil 15,000 gallon tank for hospital boiler, located on the west side of the hospital loading docks along Oglethorpe Street, about 50 feet west of the location of the 10,000 gallon heating oil tank that was removed from the site. This tank was excavated and removed from the site February 2008, through site demolition activities (Wisham, 2009). The AEC Tanks 1, 2 and 3, although they are gone from the Former Hospital site, the contaminated soils evident from one to all three of these tanks in the 1997 excavation for the hospital building expansion remain as RECs. The extent of soil contamination and type of contamination, whether from diesel or gasoline or both, should be investigated further to define and potentially remediate the soil and possible groundwater contamination. SRH Tanks 4, 5, 6 and 7 were removed from the Former Hospital site through demolition activities following the March 2007 disaster event. Winter Environmental completed a report that addresses the removal of these tanks in February 2008 (TTL, 2009). A copy of this report has not been available for FEMA review. Therefore, the potential extent of soil contamination related to these four USTs is unknown and remain as RECs. Figure 3-10 shows an aerial photo and site plan for the Former Hospital site along with the approximate locations of the 7 USTs described in the EA report with notes describing the recognized environmental concerns related to each UST. The following six (6) facilities were identified on the Georgia EPD LUST List within the AMSD of one-half mile of the Former Hospital site. Table 3-6: LUST Sites Near Former Hospital Site Site Name Address Approximate Distance Relative to Former Hospital Site Regulatory Status Patel’s Shop Rite 1036 E. Forsyth St. Southeast-east adjacent No Further Action (NFA) Eastside BP 102 Tripp Street 1,200 feet east-southeast NFA Eastside Shell Station US280 & GA49 1,200 feet east-southeast NFA Crown No. 138 311 Tripp Street >1,200 feet southeast Post Remediation Monitoring Georgia DOT 1557 E. Lamar Street >1,200 feet east-southeast NFA Goodyear ACS 225 E. Lamar Street 2,500 feet west NFA Of the six LUST sites identified within 0.50-mile of the subject property, three are located greater than 0.25-mile east-southeast of the property (Crown, Georgia DOT, and Goodyear). The Georgia DOT and Goodyear sites have been granted NFA status by the Georgia EPD. The third of these sites, Crown No. 138, is in post remediation monitoring. Based on their current regulatory status, distance removed and a review of the area topography, the LUST sites located greater than 0.25-mile from the subject property are not considered to represent a recognized environmental condition likely to adversely impact the subject property. The LUST sites identified as Eastside BP and Eastside Shell Station, are located approximately 0.25-mile east-southeast of the subject property. Based on review of the USGS topographic map of the area, topographic relief underlying the Eastside BP and Shell LUST sites slopes downward to the east toward an unnamed tributary to Mill Creek. These LUST sites are therefore considered to be located down gradient from the subject property. Each of these sites have also been issued NFA status by the Georgia EPD. For these reasons, these LUST sites are not considered to represent recognized environmental conditions likely to adversely impact the subject property. The remaining LUST site is identified as Patel's Shop Rite which was formerly located at 1036 East Forsyth Street. The 1036 address listing is located at the northeast corner of the Mayo and East Forsyth Street intersection and is currently developed with a CVS pharmacy/drugstore. The subject property is located adjacent to the west of the Patel's Shop Rite LUST site. According to regulatory information presented in the EDR report, a release was reported to EPD in April of 1996, during which time, three USTs were removed. A second release was reported to EPD during the removal of three additional tanks in August of 2006. A no further action status was issued for both releases in 2006. Interviews with EPD regulatory personnel confirmed that NFA status is granted based on confirmatory soil/groundwater sampling. Therefore, based on its current regulatory status, the Patel's Shop Rite LUST site is not considered to represent a recognized environmental condition likely to adversely impact the Former Hospital site. State Underground Storage Tank (UST) List The State Underground Storage Tank (UST) List is a listing of underground storage tank systems that are registered with Georgia EPD. The EDR report indicates that: The Sumter Regional Hospital is identified in Georgia EPD records as a UST site. Our review of regulatory information presented by EDR reveals that one 10,000-gallon UST was removed from the subject property in January of 1998. Additionally, a 3,000-gallon UST was reportedly abandoned in place at the Sumter Regional Hospital. According to interviews, the 10,000-gallon tank contained #5 fuel oil and was replaced with a 15,000-gallon fiberglass UST in 1998. The 3,000-gallon UST was abandoned in place in 1998, at which time, a 6,000-gallon fiberglass UST was installed as a replacement. No records of releases were reported with 3,000 or 10,000-gallon USTs. Apparently, there are no EPD records for the 15,000 or 6,000-gallon fiberglass tanks. In addition to the hospital, the former Americus Engineering and Construction Company is listed as a UST site. Records show that a 500-gallon and 2,000-gallon UST were removed from the ground in December of 1991. Both tanks were reportedly constructed of steel and contained diesel. As noted in the previous section, a release was discovered and a NFA status was issued for this site in 1998. The following seven (7) facilities were identified on the Georgia UST List within the AMSD of 0.25-mile relative to the subject property. Table 3-7: UST Sites Near Former Hospital Site Site Name Address Approximate Distance Relative to Former Hospital Site Patel’s Shop Rite 1036 E. Forsyth Street East-southeast adjacent Charles Wheatley Estate 804 Oglethorpe Avenue North adjacent Wayne, Inc. 1043 E. Forsyth Street 1000 feet east-southeast Depot Car Wash US280 1000 feet south Eastside BP 102 Tripp Street 1,200 feet east-southeast Americus Dist. Operations 1026 E. Lamar Street 1,200 feet southeast MTD No. 2 Get N Go 506 US280 1,200 feet southwest Two of the sites, (Patel's Shop Rite and Eastside BP) are discussed in the previous LUST section. The Charles Wheatley Estate is situated at the intersection of Oglethorpe Avenue and Mayo Street. According to EDR regulatory information, one tank was removed on December 3, 1991 with no releases reported. Based on site observations, topography underlying the Wheatley Estate property slopes downward to the north; and therefore, a potential release would not likely impact the subject property. The remaining four UST sites in the table are not located adjacent or contiguous to the subject property and no releases were reported at any of the sites. State Hazardous Waste Sites (SHWS) List The Georgia State Hazardous Waste Sites (SHWS) List is equivalent to the Federal CERCLIS List and is maintained by the Georgia EPD. The EDR report indicates that: The subject property does not appear on the SHWS List. One SHWS listing, identified as the 304 North Dudley Street site, located greater than 0.50-mile west of the subject property. Due to the distance removed from the subject property and intervening topographic features, this SHWS listing is not considered to represent a recognized environmental condition likely to adversely impact the subject property. Georgia Non-Hazardous Site Inventory (NON-HSI) List This list contains property listings that have reported contamination of soil and groundwater under the Georgia Hazardous Site Response Act (HSRA). These sites were not placed on the Georgia Priority list (Hazardous Site Inventory or HSI) because their hazard evaluation scores did not exceed the threshold levels established for sites posing an imminent threat to health or the environment. The subject property does not appear on the Georgia NON-HSI List. There were no facilities identified on the NON-HSI List within the AMSD of one mile of the subject site. 3.6.3 272-Acre Property Conditions The 272-acre property has a history of agricultural use as evident in aerial images dating back to 1937. Specifically, the majority of the site was in use agriculturally during the earliest period of review, planted with orchards in the northwest and southeast corners before 1937 and the northeast wetlands area have remained unused and wooded throughout the lower elevation areas of the site. Chain of title information does not indicate ownership of the subject tract of land by companies or entities that suggest industrial use of the property. Three farmsteads, or groups of farm buildings, were located onsite and visible in the earliest (1937) aerial image. These farmsteads were located in the southeast, southwest and central areas of the site. Review of historic information has not revealed use in such a manner that would be expected to significantly impact the environmental quality. Properties surrounding the site are in use for agricultural purposes to the west and northwest, undeveloped wetlands to the northeast, developed for commercial or retail use in the east and southeast, and in use for industrial purposes (fuel storage) to the south. With the exception of bulk fuel storage, no other surrounding land use appears to exhibit the potential to negatively impact the environmental quality of the site to the extent that a recognized environmental concern (REC), as identified by the ASTM Standard E1527-05. Although the nature of bulk fuel storage at TransMontaigne (south of the site) suggests the potential for environmental contamination, and associated impact to the groundwater resource below such a terminal facility. No information was identified that indicate the TransMontaigne terminal has contributed to historic or current degradation of the groundwater resource. Based on reported EPD and EPA investigations, assessment and inspections, that fuels storage at the facility has not resulted in environmental degradation requiring ongoing investigation and remediation. This is evident by exclusion from the EPD HSI database, and inclusion on the EPA CERCLIS NFRAP database. Septic Tanks/Cesspools No septic tanks or cesspools during the site reconnaissance (TTL, 2009b). It is possible that abandoned septic system drainfields could exist in the vicinity of one or more of the former farmsteads upon the property. If present, these drainfields would likely have been used for domestic waste disposal only and are not considered a REC. However, should a residential drainfield be identified during site clearing and development, appropriate soils testing to document if hazardous materials exist for proper disposal. Pits, Ponds, Lagoons and Surface Waters No pits, ponds, or lagoons were observed during the site reconnaissance (TTL, 2009b). Several streams were observed on-site flowing to the east in the direction of Muckalee Creek. EPA Comprehensive Environmental Response, Compensation, and Liability lnformation System (CERCLIS) List The EPA Comprehensive Environmental Response, Compensation, and Liability lnformation System (CERCLIS) List identifies documented and suspected contamination sites throughout the nation which were not ranked high enough to be listed on the NPL. The EDR report indicates that: The site does not appear on the CERCLIS List. There is one facility listed on the CERCLIS List within a one-half mile radius of the site. The TransMontaigne terminal is located south of the site on the south side of US280. This facility is listed on the CERCLIS database according to EDR, however correspondence with EPA personnel reveals that the facility has received No Further Remedial Action Planned (NFRAP) status (TTL, 2009b). CERCLIS-NFRAP is a listing of sites designated "No Further Remedial Action Planned" which have been removed from CERCLIS. NFRAP sites may be sites where, after an initial investigation, no contamination was found, contamination was removed quickly without the need for the site to be placed on the NPL, or the contamination was not serious enough to require Federal Superfund action or NPL consideration. The EDR report indicates that: The site does not appear on the CERCLIS-NFRAP List. According to the EDR report there are no facilities listed on the CERCLIS-NFRAP List that adjoin the New Hospital site. However, conversations with EPA personnel reveal that the TransMontaigne terminal, south of the site currently maintains NFRAP status on CERCLIS (TTL, 2009b). EPA Resource Conservation 8 Recovery Act Information (RCRA) List RCRA is the EPA database of facilities that generate, transport, treat, store, and/or dispose of hazardous wastes as defined by the Resource Conservation and Recovery Act. Generators and transporters are found on the RCRA List of Generators/Notifiers. Non-Generators (NonGens) do not presently generate hazardous waste. Conditionally exempt small quantity generators (CESQGs) generate less than 1000 kilograms (kg) of hazardous waste, or less than 1 kg of acutely hazardous waste per month. Small quantity generators (SQGs) generate between 100 and 1,000 kg of hazardous waste per month. Large quantity generators (LQGs) generate over 1,000 kg of hazardous waste, or over 1 kg of acutely hazardous waste per month. Transporters are individuals or entities that move hazardous waste from the generator off-site to a facility that can recycle, treat, store, or dispose of the waste. The EDR report indicates that: The site does not appear on the RCRA List. There are no facilities listed on the RCRA List within a ˝ -mile radius of the site. EPA Emergency Response Notification System (ERNS) List The EPA Emergency Response Notification System (ERNS) List is a list of hazardous material incidents reported to various State agencies. The EDR report indicates that: The site does not appear on the ERNS List. State Landfill List Lists of active and inactive landfills, artificial fills, and disposal sites are maintained by the Georgia Environmental Protection Division (EPD). The landfill listing does not include unpermitted landfills or dumps. The EDR report indicates that: The site does not appear on the Landfill List. There are no properties listed on the Landfill List within a one-mile radius of the Site. Although the EDR report did not list any landfills within one-mile of the subject site, TTL has knowledge of the Sumter County Landfill located approximately 0.7 miles west of the western site boundary on McMath Mill Road. Although there are occasional exceedences of groundwater contaminants and methane within the subsurface environment originating from the landfill, there has been no evidence that the subject site has been impacted by the landfill (TTL, 2009b). State Leaking Underground Storage Tank (LUST) List The State Leaking Underground Storage Tank (LUST) List is a listing of UST systems within the state of Georgia that have reported releases of UST contents. This list is maintained by the EPD. The EDR report indicates that: The site does not appear on the LUST List. Three LUST facilities are listed in the EDR report within the '/2 -mile ASTM recommended search distance of the subject property: 1) Express Lane #18 - Located adjacent to the Site on the southeast boundary, in the northwest corner of US19 and US280. 2) Americus Inland Texaco #819 - Located at 1204 South Martin Luther King Boulevard approximately Ľ to ˝ mile east of the Site at a significantly lower elevation from the site. 3) Westside BP - Located at 910 Martin Luther King Boulevard approximately '/4 to % mile east of the Site at an elevation significantly lower that the site. LUST facilities 2 and 3 are located sufficiently distant from the subject site and at a much lower elevation and are therefore not considered to present a threat of impact to the environmental quality of the site. LUST facility #1, Express Lane # 18 is located adjacent to the site. According to the EDR database information, this facility reported a released of petroleum fuel from their underground storage tank system in 1988. The UST site Facility ID number is 9129008 and in April of 2002 the facility was given a No Further Action (NFA) status. A NFA status is typically granted when a release or contamination occurrence has been managed by the EPD to the extent that the regulatory agency is satisfied that the incident no longer presents a threat to human health or the environment. State Underground Storage Tank (UST) List The State Underground Storage Tank (UST) List is a listing of underground storage tank systems that are registered with EPD. The EDR report indicates that: The site does not appear on the UST List. No UST facilities are listed by EDR within the Ľ - mile ASTM-recommended search distance of the subject property: Based on conversations with Georgia Department of Natural Resources personnel, the TransMontaigne terminal, south of the Site is listed on the UST (Facility I.D. 1290022) database, however, there is no file on the Site. This scenario was typical during early development of UST regulatory requirements reporting in the late 1980s and early 1990s, especially for bulk petroleum fuel storage facilities (terminals). State Hazardous Waste Sites (SHWS) List The Georgia State Hazardous Waste Sites (SHWS) List is maintained by the EPD. The EDR report indicates that: The site does not appear on SHWS List. There are no facilities listed on the SHWS List within a one-mile radius of the site: Properties surrounding the site are in use for agricultural purposes to the west and northwest, undeveloped wetlands to the northeast, developed for commercial or retail use in the east and southeast, and in use for industrial purposes (fuel storage) to the south. With the exception of bulk fuel storage, no other surrounding land use appears to exhibit the potential to negatively impact the environmental quality of the site to the extent that a recognized environmental concern (REC), as identified by the ASTM Standard E1527-05. Although the nature of bulk fuel storage at TransMontaigne (south of the site) suggests the potential for environmental contamination, and associated impact to the groundwater resource below such a terminal facility. No information was identified that indicate the TransMontaigne terminal has contributed to historic or current degradation of the groundwater resource. Based on reported EPD and EPA investigations, assessment and inspections, that fuels storage at the facility has not resulted in environmental degradation requiring ongoing investigation and remediation. This is evident by exclusion from the EPD HSI database, and inclusion on the EPA CERCLIS NFRAP database (TTL, 2009b). 3.6.4 Records Reviews and Interviews The purpose of the records review was to assess the potential presence of hazardous substance contamination as a result of activities conducted on properties within the area of the Former Hospital and New Hospital sites. During the records review, information was obtained from public agencies (Federal, state, and local) to assess whether current and past property usage within the study are may have created a potential for contamination. The search of Federal and state database listings was provided by Environmental Risk Information and Imaging Services, Inc. (ERIIS), an independent information service. Interviews and historical aerial photographs were also used to characterize the past activities on and adjacent to the sites. The study area for the records review is based on the ASTM Practice and consists of the following: The subject site for Emergency Response and Notification System (ERNS) sites. These sites have had a hazardous substance or petroleum released into the environment. The subject site and adjoining properties for registered underground storage tanks (USTs) and Resource Conservation and Recovery Act (RCRA) generators. One half mile radius for leaking USTs, state solid waste facility (SWF) landfill sites, and Comprehensive Environmental Response, Compensation and Liability Information (CERCLIS) sites. One mile radius for RCRA treatment, storage, and disposal (TSD) facilities, federal superfund sites, and sites on the state hazardous waste site (HWS) inventory. During the records review, record summaries obtained by a search database listing maintained by the United States Environmental Protection Agency (EPA) and the DRN were reviewed. 4.0 Environmental Consequences The following table summarizes the potential impacts of the Proposed Action Alternative and conditions or mitigation measures to offset those impacts. Following the summary table, any areas where potential impacts were identified will be discussed in greater detail. Table 4-1: Environmental Consequences Impacts and Mitigation[+r3] Affected Environment Impacts Mitigation Geology and Soils Minor impact from earthmoving and excavation. BMPs should be employed to reduce potential for erosion and runoff during construction. Development and site drainage plans need to account for limitations for some site soils to erode. Need to follow sediment and erosion control BMPs. Landscaping should be completed with vegetation capable of reducing stormwater runoff to downgradient wetland areas and Muckalee Creek.No impacts to geology are anticipated. Minor impacts to soils may occur during construction. Appropriate Best Management Practices (BMPs), such as installing silt fences and revegetating bare soils, would minimize runoff. Surface Water No effect: no jurisdictional streams exist on the site. BMPs should be used to reduce potential erosion and sedimentation in downgradient, jurisdictional streams off site.Temporary short-term impacts to downstream surface water are possible during construction activities. A Stormwater Pollution Prevention Plan (SWPPP) and a National Pollutant Discharge Elimination System (NPDES) permit must be obtained prior to construction. Appropriate BMPs, such as installing silt fences and revegetating bare soils, would minimize runoff. Groundwater No impacts to groundwater are anticipated. None. Floodplains Construction of hospital would comply with EO 11988 and FEMA regulations.No impacts to floodplains would occur. None. Waters of the U.S. including Wetlands No effect: no wetlands exist on the proposed 45-acre site. BMPs should be employed to reduce potential erosion and urban runoff to potential threatened or endangered species in downgradient wetland areas and Muckalee Creek.No impacts to on-site waters of the U.S., including wetlands, would occur. Appropriate BMPs, such as installing silt fences and stabilizing soils would minimize runoff into downstream water resources. Transportation There would be a minor temporary increase in the volume of construction traffic on roads in the immediate vicinity of the proposed project site. Minor, long-term impacts to traffic levels on US19 and US280 would occur as a result of increased hospital patients and facility staff accessing the proposed facility. Construction vehicles and equipment would be stored on-site during project construction and appropriate signage would be posted on affected roadways. Appropriate signage would be posted to designate the approach to the hospital facility. Roadway improvements are proposed. Additional traffic devices including traffic lights may be installed during or on completion of construction to mitigate the minor long-term impacts to traffic levels. Public Health and Safety Construction activities could present safety risks to those performing the activities. All construction activities would be performed using qualified personnel and in accordance with the standards specified in Occupational Safety and Health Administration (OSHA) regulations. Appropriate signage and barriers would be in place prior to construction activities to alert pedestrians and motorists of project activities. Hazardous Materials No effect: no evidence of hazardous waste and materials on the 45-acres Proposed New Hospital site.No hazardous materials or waste impacts are anticipated. Any hazardous materials discovered, generated, or used during construction would be disposed and handled in accordance with applicable local, state, and federal regulations. Socioeconomic Resources Beneficial effect: existing and recruited healthcare professionals, supporting staff, and businesses would return to support new hospital and community growth. It would also improve housing and business development of lands to west side of Americus.No adverse socioeconomic impacts are anticipated. None. Environmental Justice No disproportionately high or adverse effect on minority or low-income populations is anticipated. Continued same level of local hospital facilities and services at site location 0.7 mile further from Americus city center than Former Hospital site. None. Air Quality Short-term impacts to air quality would occur during the construction period. Construction contractors would be required to water down construction areas when necessary; fuel-burning equipment running times would be kept to a minimum; engines would be properly maintained. Noise Temporary impact: site preparation selected removal of forest and regrading activities, and buildings construction.Short-term noise impacts would occur at the proposed project site during the construction period. Construction would occur during scheduled hours and equipment would meet all local, state, and federal noise regulations. Biological Resources Approximately 30 acres of forest would be removed. No impacts to federally listed species are anticipated. None. Cultural Resources No effect: no historic structures identified on this 45-acre former farm site unused for about 41 years.No impacts to cultural resources are anticipated. None. Infrastructure No impacts to infrastructure None. Hazardous Waste and Materials No hazardous waste and materials are anticipated. None. 4.1 Physical Environment 4.1.1 Geology and Hydrogeology No Action Alternative This alternative would have no impact on any geological or hydrogeological conditions. Former Hospital Site and New Hospital Site Alternatives These alternatives would have no impact on any geological or hydrogeological conditions. 4.1.2 Geologic Hazards No Action Alternative This alternative would have no effect on any geologic hazards. Former Hospital Site and New Hospital Site Alternatives New construction can have adverse long-term impacts form a slight increase in sinkhole subsidence, collapse, flooding and groundwater contamination. Removal of trees and vegetation or alternation of topography could enhance the above mentioned conditions to occur. This would most likely occur during the construction phase of the project. The degree of these impacts depends on the geologic conditions at each site. Each site was examined for visual signs of sinkholes. Although none was observed, structure design should take into account the potential for sinkhole development to avoid loss of structural support for buildings and pavement. Options for mitigating sinkhole problems include: Select sites without sinkholes or unsafe cavities, if possible; Appropriate design and construction methods to safely fill sinkholes and cavities; Appropriate design and construction methods for structures that compensate for the site’s geologic hazard; and Careful attention to on-site stormwater management in site design and post-construction Although the risk of sinkhole development appears unlikely and cannot be entirely eliminated, certain design and construction measures can reduce the risk of sinkholes occurring during and after construction. 4.1.3 Topography No Action Alternative This alternative would have no impact on any topographic conditions. Former Hospital Site Alternative This alternative would potential effects on the topography of the Former Hospital site. The site is relatively flat on the east side with fairly steep slopes for building construction on the west side. Construction would include earthmoving and shallow to possibly deep excavation. Potential negative short-term impacts would be mitigated through the control of runoff and prevention of erosion using best management practices in accordance with Georgia Sediment and Erosion Control Act. Potential negative short-term and long-term impacts are related to if the investigations focused on the UST RECs reveal extensive soil contamination, large pits may be needed to remove the soils before buildings are constructed, or remediated in-place with air-sparging and soil-vapor extraction wells. If groundwater contamination is also detected a network of groundwater monitoring and extraction wells and treatment plant may be needed on site and possibly offsite to control and cleanup the groundwater. New Hospital Site Alternative This alternative would potential effects on the topography of the New Hospital site. The site is relatively flat. Construction would include earthmoving and shallow excavation. Potential negative short-term impacts would be mitigated through the control of runoff and prevention of erosion using best management practices in accordance with Georgia Sediment and Erosion Control Act. 4.1.4 Soils No Action Alternative Under this alternative, soil erosion due to wind and runoff would continue to occur in those places at the Former Hospital and New Hospital sites where vegetative cover is minimal or non-existent. This erosion would likely be minimal at the New Hospital site since the site soil types are characterized as having only slight to low erosion hazards. There is a potential for significant soil erosion on the west side of the Former Hospital site as the soil type is a Greenville sandy clay loam, characterized with 8 to 12 percent slopes and severely eroded. The destroyed hospital buildings located on the west side of the Former Hospital site were demolished. The parking lot on the east side of the site has Tifton sandy loam type soils and the asphalt pavement covering the soils has remained intact. Most of the hospital building materials and contents were removed and disposed at regulated sites. The ground surface on the west side is presently cleared of vegetation with about 20,000 cubic yards of crushed concrete debris and gravel in two piles remaining near the middle. The west side of the site should be revegetated and maintained to control potential erosion of the native soils and the piles containing 20,000 cubic yards of concrete/gravel demolition materials in this No Action Alternative. Former Hospital Site Alternative If the Former Hospital site is used for the replacement hospital there is a potential for initial construction minor to significant soil erosion on west side of the Former Hospital site as the soil type is a Greenville sandy clay loam, characterized with 8 to 12 percent slopes and severely eroded. The parking lot on the east side of the site has Tifton sandy loam type soils and the asphalt pavement covering the soils has remained intact. The ground surface on the west side is presently cleared of vegetation with 20,000 cubic yards of crushed concrete and gravel in two piles. The crushed concrete and gravel piles should be removed and/or reused for building the replacement hospital facilities. Development of the west side of the site should include revegetation and maintenance of remaining exposed soil surfaces to minimize and control potential erosion of the native soils in this Alternative. Construction should include appropriate sediment control practices, as indicated in the Georgia Sediment and Erosion Control Act. New Hospital Site Alternative According to the soil survey the New Hospital site soils are composed mainly of Orangeburg loamy sand, with about 3 acres composed of Lucy loamy sand located northwest of the planned main hospital building. These soils have low erosion hazards. Construction should include appropriate sediment control practices, as indicated in the Georgia Sediment and Erosion Control Act. Short-term and long-term sediment and erosion control should be practiced to protect the wetland ecosystems associated with the nearby unnamed intermittent streambed on the north and the Muckalee Creek area on the northeast. 4.1.5 Floodplain Management Since none of the alternative sites are in the floodplain, maintaining the status quo would not affect the floodplain. 4.2 Biological Environment 4.2.1 Plant Communities and Wildlife No Action Alternative This alternative would have no effect on plant communities and wildlife. Former Hospital Site Alternative The Former Hospital site alternative would have no effect on plant communities and wildlife. The site was extensively damaged by the March 2007 tornado disaster event and following site demolition activities the site was graded clear of vegetation. A few trees remain on site not destroyed by the tornado. New Hospital Site Alternative Development of the New Hospital site poses no impacts relative to the loss of unique habitats or large contiguous areas of forestminor impacts from removal of up to 20 acres of common, secondary growth, mixed hardwood-pine woodlands, and about 120 acres of abandoned pecan orchards.. 4.2.2 Threatened and Endangered Species Based on the field observations, it is unlikely that rare, threatened or endangered species exist at any of the proposed sites, and none of the listed species were observed at any of the sites during the field reconnaissance. No Action Alternative This alternative would have no effect on threatened or endangered species. Former Hospital Site Alternative The Former Hospital site is presently highly disturbed following the March 2007 tornado disaster event and site demolition activities. Construction of a replacement hospital at this location would have no effect on threatened or endangered species. New Hospital Site Alternative The 45-acres proposed for construction of the New Hospital, out of the 272-acre property, is unlikely to contain rare, threatened or endangered species. The 45-acre site is on the top of a hill which formerly was used for farmland up to about 1968. An old unused orchard with pecan trees lies on the south half of the site.  The north half of the site has a secondary growth, mixed hardwood-pine woodlands and, about 41 years old.  The New Hospital is planned to be constructed built in the middle of the site on the hilltop of the hill.  It will be surrounded by paved parking, and smaller associated buildings, and surrounding remaining woodlands. No wetlands are located on this 45-acre site, so no species with wetland habitat areas will be affected.  The woodland is young, so it not old enough to satisfy the habitat needs for the Red Cockaded Woodpecker. 4.2.3 Wetlands The NWI map and field reconnaissance indicate that no wetlands exist at either the Former Hospital site or the New Hospital site. Therefore, no impacts to wetlands would occur under any of the alternatives. 4.3 Human Environment 4.3.1 Land Use and Zoning No Action Alternative No changes to land use or zoning would occur under the no action alternative. Former Hospital Site Alternative No changes to land use or zoning would occur under this alternative as the site is zoned for hospital use. The site would contain the rebuilt hospital facilities and paved parking areas. New Hospital Site Alternative The 45-acre site proposed for the New Hospital was annexed and rezoned by the City of Americus in July 2009. The site annexation included the entire 45 acres, as the city boundary line essentially touched the east edge of the site, next to the Quality Inn and Waffle House businesses. The site was rezoned from farming (C-2: Commercial Overlay Zone) uses to hospital (I-N: Institutional Zone) uses. No further land use and zoning changes are required. 4.3.2 Demographics and Housing No Action Alternative This alternative would change the demographic or housing characteristics for the community. If a replacement hospital is not constructed most of the healthcare professionals would move to other communities to practice their profession. The hospital and supporting healthcare and related businesses would likely cause the community demographics to change, cause the economy to decline, and decrease the value of housing. Former Hospital Site Alternative No change would occur in this alternative as the rebuilt hospital would exist on the same site as the Former Hospital. New Hospital Site Alternative Demographics and housing is likely to change through this alternative of rebuilding the hospital on the 45-acre site. Presently the land use surrounding the site is mainly farming with small- to moderate-sized commercial and industrial businesses along US19 and US280. The development of the remaining 272-acre property may include housing and facilities related to the healthcare industry. About 70 acres of the 272-acre property will likely be designated use for wetland preservation or acceptable recreational activities. Other supporting business and housing developments are likely to eventually be built nearby surrounding the rebuilt hospital. 4.3.3 Local Economy and Employment No Action Alternative If no hospital is rebuilt most of the physicians associated with the SRH/PSMC would likely move away from Americus and work in other communities. As of August 2009, a total of 134 physicians are on the SRH roster. Most of the physicians have struggled to continue to work in Americus without a full-service hospital. Their services may be used at other nearby hospitals or medical centers, noted to be 15 to 75 miles away. Since the disaster a total of up to 14 physicians either retired or quit practicing in Americus (AG, 2009). The former SRH physicians’ manager estimates out of the 134 physicians on the roster 11 would stay, 4 would retire, and 119 would leave and take their practice outside of Sumter County (Young, 2009). The economic impact of a family physician in Georgia has been estimated to be $1,028,774 per doctor per year (Graham, 2007). Therefore, the loss of up to 119 physicians is equivalent to an economic loss of about $122 million dollars per year to Sumter County. This does not account for the likely higher economic impact of specialty physicians. It also does not account for their contribution to the generation of income for other local hospitals and nursing homes. If no hospital is rebuilt fewer jobs would be available to support the community. The Georgia Southwestern State University (GSWSU), South Georgia Technical College (SGTC), International Headquarters for Habitat for Humanity and similar institutions and businesses within Sumter County may lose students and staff, as the lack of available and quality of healthcare services would make Sumter County an unattractive community to live. Former Hospital Site Alternative A rebuilt hospital on the Former Hospital site would improve the local economy and employment. The present SRH East temporary hospital serves about 59 percent of the capacity of the Former Hospital, before the March 2007 tornado disaster, for residents from Sumter County and surrounding counties. A new hospital facility will likely draw new and more qualified healthcare physicians and staff to work in Sumter County. It is presumed the capacity of the rebuilt hospital would be equal to or exceed the capacity of the Former Hospital. As a result the local economy and employment are expected to slightly improve from the conditions evident before the March 2007 tornado disaster. A rebuilt hospital would also improve the attraction of Sumter County economy and employment for existing and new residents. GSWSU and SGTC students, faculty and staff would be assured their local and quality healthcare needs were satisfied and attract new students. Staff from the Habitat for Humanity International headquarters and other local institutions and businesses would also be assured their healthcare needs were satisfied. Sumter County would improve as a destination for retirement living and hospice facilities. New Hospital Site Alternative The location of the New Hospital site is 0.7 mile further away from Americus’ city center than the Former Hospital site. The economic and employment opportunities will remain essentially the same with no significant impact. A rebuilt hospital on the New Hospital site would improve the local economy and employment. The design to rebuild the hospital on this site includes LEED architectural and landscape features desirable to improve living and working conditions of facilities. This will set the stage to attract and retain high-skilled family and specialty physicians to Sumter County. Other buildings and businesses will also be attracted to the new opportunities near the new hospital on the west side of the City of Americus. Housing is expected to grow in this area associated with the new employment opportunities for healthcare and other present and future businesses. A rebuilt hospital would also improve the attraction of Sumter County economy and employment for existing and new residents. GSWSU students, faculty and staff would be assured their local and quality healthcare needs were satisfied and attract new students. Staff from the Habitat for Humanity International headquarters and other local institutions and businesses would also be assured their healthcare needs were satisfied. Sumter County would improve as a destination for retirement living and hospice facilities. 4.3.4 Community Facilities and Services No Action Alternative This alternative would have a negative impact on the loss of tax revenue, community facilities and services as no hospital would be rebuilt. Besides the direct loss of healthcare services, many of the associated businesses, local and county governments, and educational institutions would likely suffer economically and reduce or eliminate their facilities and services. Sumter County and neighboring county residents would travel a greater distance to obtain their required healthcare services. Some residents may not be able to afford to travel to the remote healthcare facilities. Former Hospital Site Alternative As the hospital would be rebuilt on the Former Hospital site it would have a long-term negative impact on community services in Americus. This site has limited area for construction of facilities and for new/future facilities as the community grows. This would limit the local tax base, and the growth potential of healthcare facilities, local colleges and businesses. New Hospital Site Alternative The rebuilt hospital at the New Hospital site would have a positive impact on community services in Americus. This includes a direct impact from likely development of new supporting healthcare services and resources around the New Hospital site. An indirect impact is derived from the associated new businesses and housing that will likely surround the new hospital as new land developments grow on the west side of Americus Under the proposed lease of the SRH hospital facilities, PSMC is contractually committed to continue to offer the major clinical services offered by SRH before the March 2007 tornado disaster, except for Behavioral Health Services. If independent funding sources are identified to manage operating losses Behavioral Health Services will be offered. Indigent care will be provide in full compliance with state and cooperate to provide indigent care in full compliance with state and federal law and provide medical treatment or services regardless of a patient's immediate inability to pay. PSMC made an enforceable commitment to provide health care to the disadvantaged, the uninsured and the underinsured. PSMC will also provide benefits to the community to promote improved health care with sufficient safeguards to assure continued access to affordable care and to the range of services historically provided by the SRH hospital (AG, 2009). 4.3.5 Environmental Justice EO 12898 (Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations) mandates that federal agencies identify and address, as appropriate, disproportionately high and adverse human health or environmental effects of their programs, policies, and activities on minority and low-income populations. Socioeconomic and demographic data for the project area were reviewed to determine if the proposed action would have a disproportionately high, adverse impact on any minority or low-income personspopulations. No Action Alternative Taking no action would have a negative impact on environmental justice issues. With no rebuilt hospital residents may be reluctant or not afford to travel to the remote healthcare facilities. Former Hospital Site Alternative As the hospital would be rebuilt on the Former Hospital site there would be no disproportionately high, or adverse impacts on any minority or low-income populations. The construction of the new hospital building would generally improve the quality of housing and businesses in the vicinity. The public health and safety of the neighborhoods would likely improve near the hospital. New Hospital Site Alternative In this alternative there would be no disproportionately high, or adverse impacts on any minority or low-income populations. Rebuilding the hospital at the New Hospital site would more effectively serve all populations in the community and region by providing a more accessible location through US19 and US280 with more connections to other major roads. 4.3.6 Noise Noise is generally defined as unwanted sound. Sound is most commonly measured in decibels (dB) on the A-weighted scale, which is the scale most similar to the range of sounds that the human ear can hear. The Day-Night Average Sound Level (DNL) is an average measure of sound. The DNL descriptor is accepted by federal agencies as a standard for estimating sound impacts and establishing guidelines for compatible land uses. EPA guidelines, and those of many other federal agencies, state that outdoor sound levels in excess of 55 dB DNL are “normally unacceptable” for noise-sensitive land uses including residences, schools, or hospitals (EPA, 1974). No Action Alternative Under this alternative there would be no short- or long-term impact to noise levels because no construction would occur. Former Hospital Site and New Hospital Site Alternatives Under both alternatives short-term increases in noise levels are anticipated during the construction period. This increase would be temporary and not considered significant. Equipment and machinery utilized on the project sites would meet all local, state, and federal noise regulations. Normal activities at the new facility are unlikely to affect other sensitive receptors in the area. 4.3.7 Visual Resources No Action Alternative In this alternative the Former Hospital site has an intact asphalt-paved parking lot on the east side of the site and bare ground on the west side of the site, following demolition of former hospital buildings. In addition, there are two piles of crushed concrete and gravel comprising 20,000 cubic yards that lie near the middle of the site. Under this alternative the asphalt paving, bare ground and piles of crushed concrete and gravel would remain as negative impacts to the visual resources of the community. Former Hospital Site Alternative In this alternative the impacts described in the No Action Alternative for the Former Hospital site would be improved to be a beneficial impact to the community. The rebuilt hospital and grounds would be developed in cooperation with the community to minimize potential visual impacts. New Hospital Site Alternative Rebuilding the hospital on the New Hospital site would be a beneficial impact to the community. The existing site contains regrown young forest on the north and an unused Pecan orchard on the south. Development of the hospital grounds would retain suitable trees on site in addition would add significant landscape changes to improve the visual appearance of the site. This would be in compliance with LEED design considerations. As the site will be developed with LEED design other surrounding properties likely will also adopt LEED designs improving the visual resources for the community on the west side of Americus. This will help attract and retain new physicians, other healthcare professionals and supporting businesses to this rural area. 4.4 Cultural Resources No Action Alternative Under this alternative, the public hospital would not be rebuilt. It would be a negative impact to the community cultural resources. Former Hospital Site Alternative Under this alternative, the public hospital would be rebuilt on the Former Hospital site. It would have no impact to the community cultural resources. New Hospital Site Alternative No significant cultural resources were identified through field surveys on the New Hospital site, as a result this alternative would have no impact to the community cultural resources. 4.4.1 Historic Structures As there are no historic structures involved with the alternatives there is no impact to historical structures in the community. 4.4.2 Archaeology As there are no known archaeological resources involved with the alternatives there is probably no impact to archaeological resources in the community. 4.5 4.5 Infrastructure No Action Alternative Under the No Action Alternative, no impact to water supply, wastewater treatment, or utilities is expected. Former Hospital Site and New Hospital Site Alternatives Each of these alternatives would involve the reconnection or addition of distribution lines from the existing water supply, sewer collection and natural gas utilities pipelines located at each site. Americus’ would provide these resources and no capacity issues are expected (Kendrick, 2009 and Deason, 2009). The environmental consequences of installing the distribution pipelines would be minimal. 4.5.1 Transportation No Action Alternative Under the No Action alternative there would be no effect on transportation to the community. Former Hospital Site Alternative Under the Former Hospital site alternative of rebuilding the hospital there would be no effect on transportation to the community. New Hospital Site Alternative Under the New Hospital site alternative there would be no significant impact to transportation to the community. The City of Americus Transit System includes the use of four on-call vans that can transport passengers around the community at a flat cost of $2.00 per ride. The Americus Community and Economic Development Department manages the Transit System and reported an annual average of 90 rides per day over the last 4 years, 2006 to 2009 (Young, 2009). The number or rides is expected to remain the same once the hospital is rebuilt on the New Hospital site. Two private taxi companies also exist in the city that can transport passengers at a flat cost of $5.00 per ride. Transportation within Americus is done mainly through private vehicles, secondarily by walking. Major roadway improvements to US19 are presently being completed by Georgia DOT. This involves widening the road to 5 lanes, 2-lanes each direction with a painted median/turning lane. In July 2009 new concrete curb and gutter roadway details were completed from the US19/280 intersection/merge on the north side of the road up to the southeast corner of used car dealership, located southeast of the 272-acres property. DOT plans to complete construction of a concrete sidewalk from the US19/280 intersection/merge to the driveway of the used car dealership. The new north-side highway bridge widening across Muckalee Creek includes a simple 3-feet high concrete barrier/rail and is not designed for a sidewalk. The south-side of the highway bridge presently has the older/original sidewalk and handrail across Muckalee Creek. The City of Americus plans to construct a new sidewalk along the easement of N. Martin Luther King, Jr. Blvd., towards the New Hospital site. Following the present DOT work it will tie in with the existing network of city sidewalks that end at the intersections of W. Forsyth Street/W. Lamar Street and N. Martin Luther King Jr. Blvd. As a result a continuous sidewalk will connect the hospital to the Americus network of sidewalks. 4.6 Hazardous Waste and Materials 4.6.1 No Action Alternative Conditions Under the No Action alternative, the RECs identified in Section 3.6.2, for the Former Hospital site, would be investigated to determine the extent of soil and possible groundwater contamination that underlies the site from former land use activities. This includes the soil contamination discovered in 1997 during the excavation for expansion of the hospital building; likely related to one to three former USTs used by the former construction contractor, AEC, on the northeast corner of the site. It also includes potential soil contamination from the Former Hospital’s four USTs used for diesel fuel and heating oil, located along Oglethorpe Street. If soil and/or groundwater contamination is evident and the level of liability identified, appropriate remediation measures should be conducted to eliminate these sources of contamination. 4.6.2 Former Hospital Site Alternative Conditions Through the Former Hospital site alternative the site would be investigated to determine the extent of soil and possible groundwater contamination that underlies the site as described in Section 4.6.1 No Action Alternative Conditions. If soil and/or groundwater contamination requires remediation activities, they may be designed to allow the hospital to be rebuilt. This work should be coordinated with and approved by EDP, the state regulatory agency responsible to protect the public from soil and groundwater contamination issues. Table 3-54 and Table 3-6 summarize the proximity of the LUST and UST sites in relation to the Former Hospital site. At the present time potential for LUST/UST sites to cause adverse impacts to human health or the environment is low. Further, as long as proper fuel storage, maintenance practices, and compliance with all applicable State and Federal regulations are adhered to, the likelihood o f any future petroleum release impacts to the proposed hospital. Hazardous building materials that may be discovered not removed during the 2008 hospital demolition contract would be disposed of in a permitted solid waste landfill. Standard operating procedures should be followed for removal and disposal of hazardous waste or soils. All friable and non-friable asbestos containing materials (ACM) that may become friable during excavations should be removed according to the National Emissions Standard for Hazardous Air Pollutants (NESHAP) regulations. 4.6.3 New Hospital Site Alternative Conditions No hazardous waste or materials were identified to exist on the 45-acres proposed for the New Hospital site. Therefore, no potential adverse impacts to human health and the environment are anticipated at this site from hazardous waste or materials. 4.7 Summary of Environmental Consequences None of the alternatives are expected to result in any significant adverse impacts. Many of the potentially adverse impacts described in the preceding section on environmental consequences are minor and do not require mitigation. Section 4.8 describes the mitigation actions necessary to minimize potential unavoidable adverse impacts. 4.8 Mitigation of Unavoidable Adverse Impacts Associated with the Alternatives Mitigation refers to those actions that would reduce or eliminate potential adverse environmental impacts that could occur as a result of the proposed action. Many of the potentially adverse impacts in the previous sections and the impact summary matrix (Table 2-1) are minor and do not require any formal mitigation. Construction at the sites would occur so that limitations associated with potential sinkhole development and the tendency for some soils to flood would be accounted for. Similarly, BMPs, such as erecting silt fences, would be used during construction to minimize erosion and sedimentation, in compliance with the Georgia Erosion and Sediment Control Act. Buffers should be constructed around potential live oak trees at the sites to prevent damage during construction. 4.9 Relationship Between the Short-Term Use of the Environment and the Maintenance and Enhancement of Long-Term Productivity The construction of the replacement hospital would generate economic productivity in terms of the temporary construction work created and the purchasing of materials, supplies, and services. The direct and indirect economic gain would primarily be a short-term benefit, although new housing and businesses around the new hospital could revitalize the area, creating long-term economic benefits. As the Former Hospital site is in the urban area there would be no impact on area resources. The New Hospital site is located on an insignificant area of unused farmland that does not reach a threshold for action related to the Federal Farmland Protection Act (NRCS, 2009). Area soils would be temporarily disturbed, and vegetation at the site may be lost to accommodate the site plans for public housinghealthcare facilities and new landscaping. Long-term productivity would result from the site alternatives by restoring full healthcare services to the community. The New Hospital site is located at the intersection of US19 and US280, the main traffic arteries connecting Sumter County with surrounding counties. Recent and planned improvements in US19 and US280 will make it easier to access the rebuilt hospital. The construction of the hospital using LEED design standards are likely to improve productivity and health of healthcare physicians, staff and patients. It will also help to attract and retain physicians to this rural area. 4.10 Cumulative Impacts Based upon the proposed hospital replacement project’s details above, it is apparent that this proposed project, in combination with other projects (past, present, and foreseeable future [20 years]) in and near Americus, Georgia would not have a cumulatively significant adverse impact on the human environment. 4.11 Irreversible or Irretrievable Commitment of Resources Regulations for the preparation of NEPA compliance studies require evaluation of irreversible and irretrievable commitments of resources associated with the alternatives. For the 272-acre property with the 45-acre New Hospital site, 60 acres would continue to be dedicated to wetlands. The remaining 167 acres would eventually be developed for other healthcare-related concerns and business, such as pharmacies, non-profit agencies and services, would be logical and encouraged elements for future growth. The proposed site plans include green spaces and perimeter walking trails to promote physical fitness. 5.0 Public Involvement Since the March 1, 2007 tornado disaster event, the public has been continuously engaged in the rebuilding of the hospital facilities. Sumter Regional Hospital and related health-care services are major employers and important for the vitality and continued economic growth for the City of Americus and Sumter County. The public in the surrounding communities and counties support the return of quality regional health care that was provided to them by SRH in Sumter County. A total of 13 months after the disaster the temporary hospital, SRH East, was constructed and operational with transportable modular housing units. The SRH East is an interim solution to health care for the region and it was expected that a new replacement hospital would eventually be constructed and operational. Noted in Section 3.3.4, the number of patients treated at SRH East dropped to 59 percent of the Former Hospital capacity, as patients go to other remote more full-service healthcare facilities. Americus and Sumter County constitute “small town” rural community, with the setup of the temporary hospital and building the replacement hospital as regular major local news. Public meetings, newspaper articles and local television station reports have kept the Sumter County public informed on the progress of the hospital rebuilding efforts (see Tables 5-1 and 5-2). They document numerous opportunities for the public to provide comments and questions on the proposed project and possible cultural, economic and environmental consequences. In November 2007, shortly following the March 1, 2007 tornado, voters in Sumter County approved a Special Local Options Sales Tax (SPLOST) that will last until at least 2014. This includes a 1 percent sales tax to help rebuild the hospital, among other capital improvement projects in the county.  An Americus Times Recorder article from July 28, 2007 said $3M will be derived from this fund for the hospital (Young, 2009).  Sumter County residents know their sales tax money is going towards rebuilding the hospital. As the Authority reached an agreement with Phoebe Putney to partner in rebuilding the hospital, public meetings and newspaper articles carried the news to the public of the progress of the partnership. This included numerous articles in the daily local newspaper, the Americus Recorder Times Recorder. Below is a brief listing of dates: Table 5-1: Public Meetings on Rebuilding the Sumter Regional Hospital Date Location Meeting Subject Groups Present Source 11/2/2008 Albany-Dougherty Hospital Authority Meeting Phoebe Putney Health System's proposed lease of Sumter Regional Hospital Members of Hospital Authority, PPHS representatives Albany Herald 11/11/2008 Americus Rotary Club Proposed lease of Sumter Regional Hospital by Phoebe, rebuilding the hospital at a different location Rotary Club members, PPHS representatives, SRH representatives Americus Times Recorder 11/18/208 Commission Meeting EMS Contract and Phoebe Sumter Lease County commissioners, PPHS representatives, SRH representatives, citizens Americus Times Recorder 12/22/2008 Public Hearing -- Sumter Bank & Trust Public hearing conducted by Americus and Sumter County Hospital Authority to discuss terms of lease. Public Americus Times Recorder 11/18/2008 Sumter County Board of Commissioners Strategic partnership with Phoebe, Discussion of alternate site. County commissioners, PPHS representatives, SRH representatives, citizens Americus Times Recorder 2/12/2009 Albany-Dougherty Hospital Authority Meeting Update on Phoebe Sumter facility, other business Members of Hospital Authority, PPHS representatives Albany Herald 2/13/2009 Americus Kiwanis Club Update on Phoebe/Sumter lease Kiwanis Club members, PPHS representatives Americus Times Recorder 3/4/2009 PPMH Board Meeting Update on Phoebe/Sumter lease and land purchase PPMH Representatives and Board members Albany Herald 5/13/2009 Georgia Southwestern University Public Comments Members of Hospital Authority, PPHS representatives Georgia Attorney General "Findings" Document 6/18/2009 Americus City Hall Agenda Item: 1st Public Hearing for New Hospital site Rezoning & Annexation. Americus City Council and staff, PPHS management staff & representatives. City Council Minutes 7/23/2009 Americus City Hall Agenda Item: 2nd Public Hearing for New Hospital site Rezoning & Annexation. Americus City Council and staff, PPHS management staff & representatives. City Council Minutes 8/10/2009 Americus City Hall – Joint City/ County Meeting Agenda Item: Rebuilding hospital on New Hospital site Sumter County Commissioners and staff, Americus City Council and staff, PPHS management staff. Americus Times Recorder Table 5-2: List of Local Newspaper Articles Television News on Hospital Rebuilding Date Subject/Headline Source 11/6/08 Americus hospital to open in 2011 Phoebe Putney Health System plans to lease and manage Americus’ hospital for 40 years. Albany Herald 11/6/08 Phoebe will control new Americus hospital WALB (TV) 11/8/08 Americus hospital partners with Phoebe Putney Sumter Regional Hospital reaches out for a partner to build a new 76-bed hospital, and finds Phoebe Putney Albany Herald 10/18/2008 SRH selects Phoebe Putney as partner to build new Americus hospital Americus Times-Recorder 10/31/2008 Sumter Regional Hospital announces job cuts Americus Times-Recorder 11/12/2008 Phoebe Putney CEO looks to ‘extra slice of pie’ with Sumter Regional Americus Times-Recorder 11/18/2008 SRH reps tell County: EMS won’t be their concern Americus Times-Recorder 11/25/2008 Public hearing to be held Dec 22 Americus Times-Recorder 11/27/2008 Voices - Stembridge asks about hospital Americus Times-Recorder 12/22/2008 Public hearing fails to answer public's questions Americus Times-Recorder 1/18/2009 Hospital Update-CEO talks of lease Americus Times-Recorder 1/18/2009 Phoebe Putney CEO given public questions Americus Times-Recorder 2/13/2009 Authority gets update on medical tower Albany Herald 2/14/2009 Phoebe CEO asks Americus not to be impatient Americus Times-Recorder 3/3/2009 Late Breaking News - Phoebe In Agreements For Land Americus Times-Recorder 3/3/2009 Hospital Moves Forward Americus Times-Recorder 3/4/2009 Hospital Moves Forward... Americus Times-Recorder 3/4/2009 Land selected for Sumter Regional Hospital WALB (TV) 3/5/2009 Sumter hospital project making progress Albany Herald 3/17/2009 Hospital signs deal Americus Times-Recorder 4/29/2009 Phoebe Putney names Phoebe Sumter Board Americus Times-Recorder 5/13/2009 Attorney General to hold hospital hearing Americus Times-Recorder 5/18/2009 City officials comment on new hospital Americus Times-Recorder 6/9/2009 AG OKs agreement between Phoebe, Sumter Americus Times-Recorder 6/11/2009 Requests made for rezoning of new PSMC property Americus Times-Recorder 6/18/2009 Americus City Council holds public hearings on Phoebe requests Americus Times-Recorder 7/4/2009 Local Real Estate Transactions, Phoebe pays big for land Americus Times-Recorder 7/11/2009 Real Estate Transactions Americus Times-Recorder 7/23/2009 Americus City Council gets it done Americus Times-Recorder 8/5/2009 Americus and Sumter County Hospital Authority meets Americus Times-Recorder Copies of the Draft EA were placed in two information repositories located in the City of Americus, the Clerk’s Office in the Municipal Building and the Blackshear Regional Library, for a 21-day public review and comment period starting September 16th. The Draft EA could also be viewed and downloaded from FEMA’s website: http://www.fema.gov/plan/ehp/envdocuments/ea-region4.shtm. Ads notifying the public of the availability of the Draft EA were placed in the Americus Times Recorder on September 11th and 15th. In addition, on September __, 2009, an Open House was held at Americus’ public meeting rooms at Rees Park, in the City of Americus, Georgia from 7:00 pm to 9:00 pm to provide the public the opportunity to comment on the Draft EA. Copies of the Draft EA were placed in three information repositories located in the City of Americus, and ads notifying the public of the availability of the Draft and Open House were placed in the Americus Times Recorder. No substantive negative comments have yet to been received to date. 6.0 Agency Coordination and Permits FEMA is the lead federal agency for conducting the NEPA compliance process for the proposed project in Americus, Georgia. It is the goal of the lead agency to expedite the preparation and review of NEPA documents and to be responsive to the needs of the community and the purpose and need of the proposed action while meeting the intent of NEPA and complying with all NEPA provisions. FEMA will notifiedy the public of the availability of the Draft EA through publication of a public notice in a local newspaper, the Americus Times-Recorder. FEMA will conduct an expedited public comment period commencing on the initial date of publication of the public notice. The following agencies and organizations were contacted by letter requesting project information and review during the preparation of this EA. Responses received to date are included in Appendix B. • City of Americus • Georgia Department of Archives and History (State Historic Preservation Office) • Georgia Department of Community Affairs • Georgia Department of Environmental Quality, Office of Pollution Control, Environmental Permits Division • Georgia Department of Natural Resources, Bureau of Wetlands Permitting • Georgia Department of Transportation, Environmental Division • U.S. Army Corps of Engineers, Savannah District, Albany Area Office, Regulatory Division • U.S. Department of Agriculture - Natural Resources Conservation Service (NRCS), Americus and Tifton Offices • U.S. Fish and Wildlife Service, Georgia Ecological Services West Georgia Sub-Office (Columbus – Fort Benning) Annexation and Rezoning The City of Americus concluded its second public hearing on July 20, 2009 regarding annexation and rezoning of the proposed 45-acre New Hospital site. The first public hearing was done June 18, 2009, during its regular city council monthly meeting. Farmland Protection Policy Act (FPPA) of 1981 The FPPA was created in 1981 by the federal government to ascertain the impacts of developments on farmlands, as at the time over 1 million acres per year of farmland were being taken out of production. The NRCS implemented FPPA review of the FPPA for the new hospital site. NRCS Based upon used of the WSS GIS program, the NRCS and determined the 272-acre site had the following characteristics (NRCS, 2009). (Fig.3-5a is a farmland soils map showing a WSS GIS analyses for the new hospital site): Total Acres Prime and Unique Farmland 118.3 acres Total Acres Statewide and Local Important Farmland 68.6 acres Percentage of Farmland in County or Local Govt. Unit to be Converted 0.1 percent Percentage of Farmland in Govt. Jurisdiction with Same or Higher Relative Value 60.8 percent Not Prime Farmland 32 percent Prime Farmland 43 percent Farmland of Statewide Significance 25 percent Based on the NRCS Land Evaluation Criterion Relative to Value of the Farmland to be converted, the property achieved a score of 56 points, out of a total possible points of 100. Taken together with the 27 out of 160 points from the NRCS FPPA Form - Site Assessment Criteria FEMA completed, the project has a total of 83 points. Therefore, NRCS concluded the project points did not exceed the 160 points threshold so no further action is needed. EO 11988 – Floodplain Management, 1977 FEMA reviewed the FIRM for the 272-acre property and identified about 30 acres along Muckalee Creek as designated AE-floodplain area. The northeast corner of the proposed 45-acre New Hospital site lies no closer than 400 feet from the mapped AE-floodplain area. Therefore, the proposed action will not occur in a floodplain. EO 11990 – Protection of Wetlands, 1977 The USACE reviewed the wetlands delineation survey recently conducted on the 272-acre property and agreed that 59.5 acres are now designated protected wetlands. The northwest corner of the proposed 45-acre New Hospital site lies no closer than 110 feet from the newly-designated wetlands associated with the unnamed intermittent streambed that starts near the center of the 272-acre property. The northeast corner lies no closer than 275 feet from the Muckalee Creek designated wetlands. EO 12898 – Environmental Justice for Low Income and Minority Populations, 1994 The City of Americus and Sumter County Joint Comprehensive Plan Update, 2009, provides a map of Americus with identified low income and minority populations. City and county staff identified neighborhoods have not changed since the map was first created in 1994 for the first Comprehensive Plan. These neighborhoods are field-surveyed every two years for federal or state grant opportunities to improve the neighborhoods. The 2000 census data closely matches the Americus data. Taken together these surveys indicate there is no significant impact on environmental justice issues for the proposed project. Endangered Species Act The USFWS and EPD were contacted regarding the potential for finding threatened and endangered species on the proposed project site. It is possible there are sensitive species critical habitat areas in the 272-acre property wetlands. However, as the proposed 45-acre New Hospital site was field surveyed, no critical habitat areas were found on this woody, unused abandoned farmland and pecan orchard area on a hilltop of a hill and away from wetlands. National Historic Preservation Act of 1966 The Georgia SHPO was contacted for consideration of regarding the proposed 45-acre New Hospital site’s containing valuable potential cultural and archaeological artifacts in compliance with the NHPA. The rRecent archaeological surveys did not identify any significant artifacts that would to compel them to propose further action to protect the site. In accordance with all applicable local, state, and federal laws and regulations, the applicant would be responsible for acquiring any necessary permits prior to commencstarting construction at the proposed project site. 7.0 Conclusions The proposed replacement hospital project would not have any No significant, adverse impacts to geology, groundwater, floodplains, public health and safety, hazardous materials, socioeconomic resources, environmental justice, or cultural resources are anticipated under the Proposed Action Alternative. During the project construction period, short-term impacts to soils, surface water, transportation, air quality, and noise are anticipated. All project short-term adverse impacts will would be mitigated ustilizing BMPs, such as silt fences, proper vehicle and equipment maintenance, and appropriate signage. No long-term adverse impacts are anticipated as a result of from the proposed project. The proposed project would reduce nearby floodplain future occupancy within the floodplain. (Would likely preserve approximately about 70 acres of wetlands and adjacent areas from commercial or residential development within the 272-acre property.) 8.0 References Americus, City of, 2009, Official City of Americus, Georgia Web Site, http://www.cityofamericus.net/, Accessed August, 2009. Authority, 2008. Americus and Sumter County Hospital Authority and Phoebe Putney Health System, Inc., “Letter of Intent”, October 17, 2008. Authority, 2009. Americus and Sumter County Hospital Authority, Phoebe Sumter Medical Center, Inc., and Phoebe Putney Health System, Inc., “Agreement on Financial Terms for Construction of Phoebe Sumter Medical Center Between Putney Health System, In. and Americus and Sumter County Hospital Authority”, June 30, 2009. Butcher, Beverly, 2009. Personal communication – GIS Manager for the City of Americus and Sumter County interactive GIS internet web site, http://americus.binarybus.com, July 24, 2009. Campbell, Richard, 2009. Personal communication – South Water Treatment Plant Operator for the City of Americus Public Works Department, July 24, 2009. Carter, Burt, Ph.D., 2009. Personal communication – Professor Burt Carter with the Georgia Southwestern State University in Americus, Georgia, July 23, 2009. City-Data.Com, 2009. Internet web site for U.S. Demographics, Accessed August, 2009. Environmental Protection Agency (EPA). 1974. EPA Identifies Noise Levels Affecting Health and Welfare. http://www.epa.gov/history/topics/noise/01.htm. Accessed Federal Emergency Management Agency (FEMA). 2009. Flood Insurance Rate Map, Sumter County, Georgia and Incorporated Areas. Panel 134 of 375, Community Panel Number 13262C0134 C. Map Revised September 11, 2009. http://msc.fema.gov/webapp/wcs/stores/ Accessed July 20, 2009. Georgia Attorney General, 2009, Report on Findings – In the Matter of: The Lease of Sumter Regional Hospital by Americus and Sumter County Hospital Authority, to Phoebe Sumter Medical Center, Inc., with Phoebe Putney Health System, Inc. as Guarantor, No. AG 2009-1, June 8, 2009. Georgia Attorney General, 2009, Amendment to Report on Findings – In the Matter of: The Lease of Sumter Regional Hospital by Americus and Sumter County Hospital Authority, to Phoebe Sumter Medical Center, Inc., with Phoebe Putney Health System, Inc. as Guarantor, No. AG 2009-1, June 12, 2009. Georgia Department of Community Affairs (DCA), 2009. Rules of Georgia Department of Community Affairs, Chapter 110-12-3 Developments of Regional Impact (Effective Date: July 1, 2009) Georgia Department of Natural Resources (DNR), 1976. Physiographic Map of Georgia, William Z. Clark and Arnold C. Zisa. http://georgiainfo.galileo.usg.edu/physiographic/physio-dist.htm Georgia Department of Natural Resources (DNR), 2008, Environmental Protection Division (EPD), 2008. Fact Sheet – State of Georgia DNR EPD National Pollutant Discharge Elimination System General Permits No. GAR100001, No. GAR100002, and No. GAR100003 for Storm Water Discharges Associated with Construction Activity, June 9, 2008. Georgia Department of Transportation (DOT), 2009, Personal communication with Mr. Robbie Albritton, DOT Field Engineer for U.S. Highway Widening Project, August 7, 2009. Habitat for Humanity (Habitat), 2009, Announcement – Habitat for Humanity International and the Home Depot Foundation Announce National Expansion of ‘Partners in Sustainable Building, joint announcement with the Home Depot Foundation, August 4, 2009. Halford, Brad, 2009, Phoebe Sumter Medical Center, Chief Compliance Officer, Personal communication, August 11, 2009. KLMK Group, 2009a, Phoebe Sumter Hospital Site Due Diligence Report Appendix. Kendrick, Bernard, 2009. Public Works Director for the City of Americus, Georgia Public Works Department, July 26, 2009. Khalequzzaman, Ph.D., Md, 2002, Water Quality of Muckalee Creek in Sumter and Lee Counties, Georgia, Department of Geology & Physics, Lock Haven University, Lock Haven, Pennsylvania. Lanier Engineering, Inc., 2008, Wetlands Survey Property of Thomas Barr, Part of Land Lots 153, 154, 177, 178, & 183, Twentyseventh Land District, City of Americus, Sumter County, Georgia, December 23, 2008. Lanier Engineering, Inc., 2009, ALTA/ACSM Land Title Survey Prepared for Phoebe Putney Health System, Inc., Lawyers Title Insurance Corporation, Old Republic Title Insurance Company and Watson, Spence LLP, January 28, 2009. Rigsby, Anna., 2009, City of Americus Community & Economics Development Assistant Director, Personal communication, August 10, 2009. Risk Tech, LLC, 2007, Sumter Regional Hospital, Hazardous Materials Remediation, Americus, Georgia, Risk Tech, LLC, 669 Marina Drive, Suite B-1, Charleston, South Carolina, April 19, 2007. Robert E. Perry & Associates, Inc. (Perry), 2009. Report of Phase I Cultural Resources Reconnaissance of an Approximate 34-Acre Tract, Americus, Sumter County, Georgia, for TTL, Inc., March 30, 2009. Robert Graham Center for Policy Studies, 2007, Economic Impact of Family Physicians, State-by-State Report for the American Academy of Family Physicians, June 2007, http://www.aafp.org/online/etc/medialib/aafp_org/documents/policy/state/econimpact/ga.Par.0001.File.tmp/Georiga.pdf Stevens & Wilkinson of Georgia, Inc., 1997, Site / Staking Plan, Expansion & Renovation Sumter Regional Hospital, Americus, Georgia, September, 29, 1997. Sumter County, 2009, Joint Comprehensive Plan – Partial Plan Update for Sumter County, including the Cities of Americus, Andersonville, DeSoto, Leslie and Plains. TTL, 2008. Preliminary Geotechnical Report, Phoebe Putney Memorial Hospital Sumter Regional Hospital – Site Option #2, Americus, Sumter County, Georgia, December 22, 2008. TTL, 2009a. Report of Threatened and Endangered Species Survey Jurisdictional Wetlands and Streams Survey Limited Survey of Cultural Resources, Phoebe Sumter Hospital Replacement Campus Project, Americus, Sumter County, Georgia, January 8, 2009. TTL, 2009b. Report of Phase I Environmental Site Assessment, Phoebe Sumter Hospital Replacement Campus Project, Americus, Sumter County, Georgia, January 9, 2009. TTL, 2009c. Phase I Environmental Site Assessment Report, Sumter Regional Hospital Properties: Former Sumter Regional Hospital Site 12.5+/-Acres 100 Wheatley Drive, Americus, Georgia, for Sumter Regional Hospital, June 5, 2009. U.S. Army Corps of Engineers (USACE). 1987. Corps of Engineers Wetland Delineation Manual. U.S. Census Bureau (USCB). 2000. Urbanized Area Fact Sheet (Census 2000) Americus, GA, http://factfinder.census.gov/servlet/SAFFFacts?_event=Search&geo_id=&_geoContext=&_street=&_county=Americus&_cityTown=Americus&_state=04000US13&_zip=&_lang=en&_sse=on&pctxt=fph&pgsl=010&show_2003_tab=&redirect=Y. USCB. 2009. 2005-2007 American Community Survey 3-Year Estimates. http://factfinder.census.gov/. Accessed August 4, 2009. U.S. Department of Agriculture (USDA)/ Natural Resources Conservation Service (NRCS). 2008. Web Soil Survey (WSS). http://websoilsurvey.nrcs.usda.gov/app/ Modified November 13, 2008. Accessed July, 2009. USDA/NRCS, 2009. Plants Database – Wetland Indicator Status, http://plants.usda.gov/wetland.html August, 2009. U.S. Department of Housing and Urban Development (HUD), 2009. Memorandum – HOME Program Income Limits – 2009, March27, 2009. U.S. Department of Interior National Park Service (NPS), 2009, National Register of Historic Places (NRHP), http://www.nps.gov/history/nr/research/ http://nrhp.focus.nps.gov/natreg/docs/Download.html U.S. Environmental Protection Agency (EPA), 2009. Kinchafoonee-Muckalee Watershed – 03130007 http://georgiainfo.galileo.usg.edu/physiographic/physio-dist.htm U.S. Fish and Wildlife Service (USFWS). 2009. Georgia: List of Threatened and Endangered Species by County – Updated 2004. http://www.fws.gov/athens/endangered/counties/sumter_county.html Accessed August 7, 2009. USFWS. 2009. National Wetlands Inventory Maps. http://www.fws.gov/wetlands/Data/mapper.html. Through “The National Map” http://nmviewogc.cr.usgs.gov/viewer.htm Accessed July 25, 2009. U.S. Geological Survey (USGS), 1986. National Water Summary – Ground Water Quality: Georgia. U.S. Geological Survey (USGS), 2009. Georgia Geologic Map Data, http://tin.er.usgs.gov/geology/state/sgmc-unit.php?unit=GAEOc;1 Digitized Geological Map of Georgia: after Lawton, D.E., and others, 1976, Geologic Map of Georgia: Georgia Geological Survey, scale 1+500.000, Accessed August 3, 2009. University of Georgia (UGA), 2005, UGA Tifton Campus NESPAL River Basin Fact Sheet 2 – River Basins of Georgia, http://nespal.cpes.peachnet.edu/SIRP/research/WatershedFactsheet2.pdf April 4, 2005 Wisham, Hershel, 2009, Personal communication, Phoebe Sumter Medical Center, Plant Manager, August, 2009. Young, Mandy R., 2009, City of Americus Community & Economics Development Director, Personal communication, August 10, 2009.